AFFIDAVIT OF AZRA M. HADZIMEHMEDOVIC IN SUPPORT OF SKYHOOK WIRELESS, INC.’S MOTION TO COMPEL GOOGLE INC. TO PRODUCE MR. PATRICK BRADY FOR A DEPOSITION AND TO PRODUCE CERTAIN DOCUMENTS RESPONSIVE TO SKYHOOK’S DOCUMENT REQUESTS

Case 1:10-cv-11571-RWZ Document 196 Filed 07/01/13 Page 2 of 7

I, Azra M. Hadzimehmedovic, declare as follows: 1. I am an attorney at the law firm of Tensegrity Law Group LLP, counsel of record

for Skyhook Wireless, Inc. (“Skyhook”) in the above-captioned matter. I am an attorney in good standing licensed to practice in the State of California and the District of Columbia and admitted to practice before this Court pro hac vice in the above-captioned matter. I submit this

declaration in support of Skyhook’s Motion to Compel Google Inc. To Produce Mr. Patrick Brady for a Deposition and To Produce Certain Documents Responsive to Skyhook’s Document Requests. I am personally familiar with the facts stated herein, and, if called as a witness, could testify competently hereto. 2. An electronic search of Google’s production, using Patrick Brady as a custodian

in the patent infringement case, yields 6648 documents. Mr. Brady’s corporate deposition in Skyhook’s state law case of tortious interference took place on November 4-5, 2011, and his individual deposition took place on January 31, 2012. Mr. Brady’s documents, naming him as a custodian in the federal patent infringement case, were produced on March 29, 2012. 3. I met and conferred with Google’s counsel Sanjeet Dutta regarding the TracBeam

litigation document request at least twice telephonically and I sent Google’s counsel additional written correspondence on this issue. Skyhook’s request for production of documents Google has produced in the TracBeam litigation is as follows: All Documents or Things produced or made available for inspection in TracBeam, L.L.C. v. Google, Inc., Case No. 6:13-cv-00093, including without limitation depositions and discovery responses.” Ex. 6 to this Affidavit at 120. In the two telephonic discussions with Mr. Dutta, I explained that Skyhook was particularly interested in Google’s depositions and discovery responses from that litigation (as Skyhook’s request specifically stated in the “including” clause). I explained Skyhook’s belief that the 2

Case 1:10-cv-11571-RWZ Document 196 Filed 07/01/13 Page 3 of 7

burden of turning over those limited, specific documents could not be significant. Litigation teams usually keep these files in folders that are easily accessible and well organized. I also explained the apparent overlap in the accused products between this case and TracBeam’s allegations against Google in that case, both of which involve Google’s location-based products and services. I also stressed that there may be overlapping damages issues, all of which

warranted production of corporate and individual depositions of all witnesses. Finally, I also underscored Skyhook’s continued concern with Google’s unwillingness to provide complete discovery into the roles of Google’s employees most knowledgeable about particular specific areas identified in Skyhook’s interrogatories and corporate topics. In particular, I reminded Mr. Dutta about Skyhook’s belief that Google has not provided sufficient discovery into its marketing, distribution and sales of the accused products, including the identification of persons involved in those activities and descriptions of their roles. After Google confirmed that it would produce some depositions from TracBeam litigation, I also requested that Google identify individuals whose depositions it was not willing to produce to Skyhook and the roles of those individuals. Google refused to provide identity of witnesses whose corporate or individual depositions Google was withholding and refused to provide discovery responses from the TracBeam litigation. 4. Attached hereto as Exhibit 1 is a true and correct copy of Google Inc.’s Responses

to Skyhook’s First Set of Interrogatories, dated January 6, 2011. 5. Attached hereto as Exhibit 2 is a true and correct copy of email exchange between

Attached hereto as Exhibit 3 is a true and correct copy of email exchange between

A. Hadzimehmedovic (counsel for Skyhook) and S. Dutta and T. Lundin (counsel for Google) re: Skyhook v. Google: Various Discovery Issues, dated between June 18, 2013 and June 24, 2013 7. Attached hereto as Exhibit 4 is a true and correct copy of an email from A.

Responses to Skyhook’s Third Set of Requests for Production (Nos. 176-316), dated May 2, 2013. 10. Attached hereto as Exhibit 7 is a true and correct copy of email exchange between

A. Hadzimehmedovic (counsel for Skyhook) and T. Lundin and S. Dutta (counsel for Google) re: Skyhook v. Google: ESI and Mr. Brin’s Documents, dated between May 24, 2013 and June 3, 2013. 11. Attached hereto as Exhibit 8 is a true and correct copy of a screenshot of a

photograph of Sergey Brin with Steve Jobs at the 2008 Macworld Conference & Expo (http://www.zimbio.com/photos/Sergey+Brin/Steve+Jobs+Delivers+Keynote+Speech+Macworl d/SxICtx3779p). 12. Attached hereto as Exhibit 9 is a true and correct copy of email exchange between

between S. Dutta (counsel for Google) and A. Hadzimehmedovic (counsel for Skyhook) re: Skyhook v. Google: ESI Terms, dated between June 18, 2013 and June 27, 2013. I declare under penalty of perjury that the foregoing is true and correct, and that this affidavit is executed on July 1, 2013 at McLean, VA.

CERTIFICATE OF SERVICE I hereby certify that I caused a true and correct copy of the foregoing to be served via the ECF system of the District of Massachusetts this 1st day of July, 2013, on all counsel of record. /s/ Azra M. Hadzimehmedovic Azra M. Hadzimehmedovic

7

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EXHIBIT 1

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS SKYHOOK WIRELESS, INC., Plaintiff and Counterclaim-Defendant, v. GOOGLE INC., Defendant and Counterclaimant. ) ) ) ) ) ) ) ) ) ) ) )

Case No. 1:10-cv-11571-RWZ

GOOGLE INC.’S RESPONSES TO SKYHOOK, INC’S FIRST SET OF INTERROGATORIES Pursuant to Federal Rule of Civil Procedure 33, Defendant Google Inc. (“Google”) responds and objects to Plaintiff Skyhook, Inc.’s (“Skyhook”) First Set of Interrogatories (“Interrogatories”) as follows: GENERAL OBJECTIONS 1. These responses are made solely for the purpose of this action. Each

response is subject to all objections as to competence, relevance, materiality, propriety and admissibility, and to any and all other objections on any grounds that would require the exclusion of any statements contained in these responses if such interrogatory response were asked of, or statements contained in the response were made by, a witness present and testifying in court, all of which objections and grounds are expressly reserved and may be interposed at the time of trial. 2. Discovery in this matter is ongoing. Accordingly, the following responses

are given without prejudice to Google’s right to produce evidence of any subsequently discovered fact or facts that it may later recall or discover. Google further reserves the right to

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change, amend, or supplement any or all of the matters contained in these responses as additional facts are ascertained, analyses are made, research is completed, and contentions are made. 3. Objections to the Interrogatories are made on an individual basis below.

Google’s response to each interrogatory is submitted without prejudice to, and without in any way waiving, the General Objections listed here, but not expressly set forth in that response. The assertion of any objection to an interrogatory in any response below is neither intended as, nor shall in any way be deemed, a waiver of Google’s right to assert that or any other objection at a later date. 4. No incidental or implied admissions are intended by these responses. That

Google has answered or objected to any interrogatory should not be taken as an admission that Google accepts or admits the existence of any “facts” set forth or assumed by such interrogatory. That Google has answered part or all of any interrogatory is not intended to be, and shall not be construed to be, a waiver by Google of any part of any objection to any interrogatory. 5. Google objects to the Interrogatories (which include the Definitions and

Instructions that proceed them) and to each Interrogatory to the extent that they are vague, ambiguous, overly broad, unduly burdensome, or oppressive, or seek information that is neither relevant to the issues in this case nor reasonably likely to lead to the discovery of admissible evidence. 6. Google objects to the Interrogatories and to each Interrogatory on the

ground and to the extent that they purport to seek information protected by the work-product doctrine, attorney-client privilege or any other privilege or restriction on discovery. To the extent that any interrogatory is so vague or ambiguous that it may be interpreted to call for privileged or protected information, Google interprets each such request not to call for any privileged or protected information. 7. Google objects to the Interrogatories and to each Interrogatory to the

extent they seek information in the possession, custody, or control of individuals or entities other

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than Google on the grounds they are unduly burdensome and oppressive, and such information is equally available to Skyhook. 8. Google objects to the Interrogatories and to each Interrogatory to the

extent that they seek information already within Skyhook’s possession, custody, or control on the grounds that they are duplicative, unduly burdensome, and oppressive, and such information is equally available to Skyhook. 9. Google objects to the Interrogatories and to each Interrogatory to the

extent they purport to impose on Google obligations that differ from or exceed those required by the Federal Rules of Civil Procedure, Local Rules, or the Court’s orders. Google will not comply with any purported obligation not imposed by law. 10. Google objects to the Interrogatories and to each Interrogatory to the

extent they contain discrete subparts in violation of LR 26.1(c). Skyhook’s Interrogatories contains no fewer than 4 interrogatories and discrete subparts. 11. Google objects to the Interrogatories and to each Interrogatory to the

extent they call for information related to Google’s business activities outside the United States. Skyhook’s rights under the patents-in-suit, if any, are limited to the United States. 12. Google objects to the Interrogatories and to each Interrogatory to the

extent they incorporate or reference Skyhook’s overbroad, vague and ambiguous definition of “Google Location” and “Google Wi-Fi Location Database.” 13. Google objects to the Interrogatories and to each Interrogatory to the

extent they seek the disclosure of information that constitutes Google’s trade secrets or confidential information. Information constituting Google’s trade secrets or confidential information will be produced only after entry of a protective order satisfactory to Google and only if directly relevant to disputed allegations or contentions in the pending action. 14. Google objects to the Interrogatories and to each Interrogatory to the

extent they purport to seek discovery regarding claims not identified or asserted by Skyhook. Google will respond only with regard to the asserted claims.

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15.

The foregoing general objections shall be applicable to and included in

Google’s responses to each and every one of Skyhook’s interrogatories, whether or not specifically raised below. The objections set forth below are not a waiver, in whole or in part, of any of the foregoing general objections. OBJECTIONS AND RESPONSES TO SPECIFIC INTERROGATORIES Subject to the foregoing General Objections, and pursuant to the agreement of the parties, Google responds to each separate interrogatory as follows: INTERROGATORY NO. 1: Identify the five individuals, at least three of whom are present employees, whom You believe to be the most knowledgeable regarding each of the following topics: (a) the research and development of Google Location; (b) the structure, operation, and function of Google Location; and (c) sales and marketing in the United States of Google Location, and describe each individual's knowledge and the bases for that knowledge. RESPONSE TO INTERROGATORY NO. 1: Google objects to this interrogatory as vague and ambiguous, particularly with regard to the phrases “research and development of Google Location,” and “sales and marketing in the United States of Google Location.” Google further objects to this interrogatory to the extent it contains multiple subparts in violation of LR 26.1(c). Google objects to this request to the extent that it calls for production of confidential or proprietary information, trade secrets, future marketing, and business plans. Google objects to this interrogatory to the extent it purports to require Google to speculate. Google objects to this interrogatory to the extent it is redundant of Google’s initial disclosures.

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Google objects to this interrogatory to the extent it calls for the indentification of an arbitrary and irrelevant number of individuals. Google will identify individuals who are reasonably likely to have significant, relevant information. Google objects to this interrogatory as premature and unduly burdensome. At this state of the case, it is impossible to identify with precision persons who do or do not have information relevant to the parties’ claims and defenses. Skyhook has not identified the specific accused insturmentality, identified the asserted claims, nor articulated its damages theory, and has yet to produce even a single document. Google reserves the right to supplement its response to this interrogatory as provided by Federal Rule of Civil Procedure 26. Response to Interrogatory No. 1(a) (research and development witnesses): Subject to its objections, and without waiving any objections, Google identifies the following persons whom Google believes are likely to have discoverable information regarding the research and development of Google Location: • Zhengrong Ji, knowledge of “research and development of Google Location,” based on personal knowledge derived from work on Google Location; • Arunesh Mishra, knowledge of “research and development of Google Location,” based on personal knowledge derived from work on Google Location; • Phil Gossett, knowledge of “research and development of Google Location,” based on personal knowledge derived from work on Google Location; and • Tsuwei Chen, knowledge of “research and development of Google Location,” based on personal knowledge derived from work on Google Location. Google reserves the right to supplement its response to this interrogatory as provided by Federal Rule of Civil Procedure 26. Response to Interrogatory No. 1(b) (structure, operation, and function witnesses): Subject to its objections, and without waiving any objections, Google identifies the following persons whom Google believes are likely to have discoverable information regarding the structure, operation, and function of Google Location:

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•

Zhengrong Ji, knowledge of “the structure, operation, and function of Google Location,” based on personal knowledge derived from work on Google Location;

•

Arunesh Mishra, knowledge of “the structure, operation, and function of Google Location,” based on personal knowledge derived from work on Google Location;

•

Ken Norton, knowledge of “the structure, operation, and function of Google Location,” based on personal knowledge derived from work on Google Location;

•

Tsuwei Chen, knowledge of “the structure, operation, and function of Google Location,” based on personal knowledge derived from work on Google Location; and

•

Marc Stogaitis, knowledge of “the structure, operation, and function of Google Location,” based on personal knowledge derived from work on Google Location.

Google reserves the right to supplement its response to this interrogatory as provided by Federal Rule of Civil Procedure 26. Response to Interrogatory No. 1(c) (sales and marketing witnesses): Subject to its objections, and without waiving any objections, Google identifies the following persons whom Google believes are likely to have discoverable information regarding sales and marketing in the United States of Google Location: • Patrick Brady, knowledge of “sales and marketing in the United States of Google Location,” based on personal knowledge derived from work on Google Location; and • Ken Norton, knowledge of “sales and marketing in the United States of Google Location,” based on personal knowledge derived from work on Google Location. Google reserves the right to supplement its response to this interrogatory as provided by Federal Rule of Civil Procedure 26. INTERROGATORY NO. 2: Set Forth The Complete Basis For Your allegations that You have not willfully infringed the Patents-in-Suit, including those allegations made in the Answer.

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RESPONSE TO INTERROGATORY NO. 2: Google objects to this interrogatory as vague and ambiguous. Google objects to this interrogatory to the extent that it calls for information protected by the attorney-client and/or work product privileges. Gooogle objects to this interrogatory as premature. To date, Skyhook has not disclosed any basis whatsoever for any claim that Google has willfully infringed any of the Patents-in-Suit. Subject to its objections, and without waiving any objections, Google states that Skyhook has not identifed any evidence that Skyhook put Google on notice of any alleged infringement.

I, John LaBan·e, declare under penalty of perjury that I am Litigation Counsel for Google Inc. and am authorized to make this Verification on its behalf. I have read Google Inc.'s Responses To Skyhook Inc.'s First Set Oflnterrogatories dated January 6, 2011, know its . contents, and, to the best of my knowledge, information, and belief, formed after a reasonable inquiry, the response is true and accurate as of the time submitted on January 6, 2011. Signed this 6th day of January, 2011 in Mountain View, CA.

Case 1:10-cv-11571-RWZ Document 196-1 Filed 07/01/13 Page 11 of 11

CERTIFICATE OF SERVICE I hereby certify that on January 6, 2011, I served the forgoing Responses To Skyhook Inc.’s First Set Of Interrogatories via email to the following:

Thanks for your message. I am in depositions tomorrow, but Sanj is available any time during the range that you suggest. Please send a meeting notice to Sanj with dial-in information. Thanks. Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134 tlundin@kslaw.com

Tom,
I
have
tried
to
reschedule
my
other
commitments
so
that
we
could
do
a
call
at
4
PM
today,
as
you
proposed, but
I
was
not
able
to
do
so.
I
am
available
tomorrow
between
4
and
6
PM
Eastern.
Please
let
me
know
if
that
works.
Thank
you.
Best,
Azra

Azra – Further to my below message, please note the following: Depositions 1. In your June 13 email message, Skyhook requested the deposition of Mr. Zelinka on July 10. Google accepts that date. Mr. Zelinka will be made available at King & Spalding’s Redwood Shores offices. 2. In the same message, you confirmed that Google would not be making Messrs. Stogaitis or Williams available on the dates (June 17 and 19, respectively) noticed in Skyhook’s individual deposition notices served May 23. That is correct. Google is working to determine dates on which Messrs. Stogaitis and Williams will be made available. Further, with respect to Skyhook’s individual deposition notices, Google is requesting a meet and confer to discuss the depositions of Messrs. Brady and Lee, each of whom was deposed in the State case – Mr. Brady over multiple days. Please be prepared to discuss what testimony Skyhook is seeking from these persons beyond the testimony provided in the State case. Absent some compelling need that Skyhook can show, Google believes that it is unduly burdensome for Skyhook to attempt to require these persons to appear for deposition again in this action. 3. Google is confirming availability to take the Skyhook depositions on the dates that you offered, with the exeption of Mr. Morgan, and we expect to be able to let you know in the next day or so. With respect to Mr. Morgan, Skyhook’s offered date is unacceptable because it is a day before the close of claim construction fact discovery. Mr. Morgan is an inventor on asserted patents for which the parties need to conduct claim construction fact discovery. Further, Mr. Morgan is a founder of Skyhook and former CEO, with essential knowledge about all of the patents in suit. In view of the claim construction fact discovery deadline, Skyhook needs to make Mr. Morgan available in July. Bain/Agarwal Subpoenas We have explained why Google is seeking information such as “documents concerning companies that compete with Skyhook" and "documents defining or describing the market in which Skyhook products compete, and the market share of Skyhook or its competitors” from Bain and Mr. Agarwal – because Bain is an investor in Skyhook and Mr. Agarwal is a Bain employee and Skyhook board member. As I explained to you in my previous message, these facts make Bain and Mr. Agarwal markedly distinct from other third parties, such as Apple, which is the only third party to have responded to a Google document subpoena in this matter. As to “how [Google] would expect a third party to search for and find documents on these and the other requests,” we would expect Bain and Mr. Agarwal to search hard copy files, and “shared sources” and emails for documents responsive to the requests.
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Case 1:10-cv-11571-RWZ Document 196-2 Filed 07/01/13 Page 4 of 9

Skyhook’s Third RFPs During our previous two meet-and-confers on Skyhook’s Third RFPs, you requested that Google consider various proposals, confirm various positions, and provide you with final responses/positions. Certain of those final responses/positions are as follows: RFP 226: Google produced additional documents last week. RFP 227: Google has confimed that it has no responsive documents. RFP 203: We believe that Google’s ESI search terms would have captured any responsive documents, consistent with Google’s response. You stated that Google’s response was inconsistent with its response to RFP 27 and requested that Google supplement RFP 27 to be consistent. Google will do so. RFP 210: We understand that there were two remaining issues: First, based on Skyhook’s definition of “Google Location,” whether Google has produced/will produce documents concerning “Google phones, laptops, and tablets.” Google will produce responsive documents for devices that Google directly sells that use Google Location Services. Second, with respect to this and other RFPs, whether Google would reconsider its objection to producing “worldwide” data. Google maintains its objection to producing “worldwide” data. RFPs 254/255: Google has confirmed that there are no non-privileged documents responsive to these requests. RFP 303: We understand that in this request, Skyhook seeks all discovery in the Tracbeam litigation. Google’s position is unchanged that this request is overbroad, unduly burdensome, seeks irrelevant documents, and not calculated to lead to the discovery of admissible evidence relevant to the claims and defenses in this action, including without limitation because the asserted patents in the Tracbeam action are not the same as the asserted Skyhook patents in this action. Nevertheless, Google is willing to produce (1) documents produced in Tracbeam that have not been produced in this action and (2) transcripts of depositions taken in the Tracbeam action for witnesses who are common to both actions. To the extent that Skyhook seeks documents, discovery responses, or deposition transcripts beyond that scope, please explain what exactly Skyhook is seeking and why it allegedly is relevant. RFP 305: Google believes that it has produced any responsive documents. RFP 307: Google has confimed that it does not have responsive documents in its possession, custody, or control. RFP 311: Google maintains its objection that this request seeks irrelevant documents, and not calculated to lead to the discovery of admissible evidence relevant to the claims and defenses in this action. Further, Google does not believe that it has any information, beyond publicly available third party reporting, concerning Google’s market share for mobile advertising. Nevertheless, Google is confirming again and agrees to produce any such documents that exist. RFP 312: Following the parties meet-and-confer, and Skyhook’s attempt to explain the relevant of this request, Google maintains its objection that this request seeks irrelevant documents, and not calculated to lead to the discovery of admissible evidence relevant to the claims and defenses in this action. RFPs 313/314: Google has confirmed that it does not track or maintain documents and information sought in the ordinary course of business. Google does not have responsive documents in its possession, custody, or control. RFP 315: Google does not believe that it has any responsive documents. Google is confirming again and agrees to produce any such documents that exist. ESI issues
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Case 1:10-cv-11571-RWZ Document 196-2 Filed 07/01/13 Page 5 of 9

1. Skyhook’s Proposed New Search Terms (Skyhook II patents) and Proposed Amended Search Terms (amending initial federal terms): As I have explained in our previous conferrals, Google has been analyzing Skyhook’s proposals. In each instance, Google believes that Skyhook’s proposals result in an overly broad and unduly burdensome scope – more so for Skyhook’s proposed new terms than for Skyhook’s proposed amended terms. Google is formulating a counter proposal in each instance that Google believes will result in a reasonable scope. Google believes that it will be able to provide such a proposal in the next several days. 2. Skyhook’s June 3 proposal concerning Sergey Brin’s documents: We previously advised you that, although Skyhook has made no showing of any basis to search Mr. Brin’s documents, Google searched Mr. Brin’s emails for Skyhook, Ted Morgan, and MacWorld and there were no relevant documents. In response, you proposed several additional terms that Skyhook contended Google should use to search Mr. Brin’s documents, including “(Mike or Michael) w/3 Shean” and “(Ted or Edward) w/3 Morgan.” Google has now searched Mr. Brin’s emails for the following: “Skyhook,” “Morgan,” “Shean,” and “MacWorld” – each of which is broader than the searches Skyhook requested. No relevant documents resulted from these searches. Google maintains its objection to any further searching of Mr. Brin’s documents. Please let us know when you are available to confer concerning the responses to the Bain and Agarwal subpoenas, including dates of production. Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134 tlundin@kslaw.com
From: Lundin, Tom Sent: Monday, June 17, 2013 2:04 PM To: Azra Hadzimehmedovic; dl.zzmgoogleskyhookext@bingham.com; Google/Skyhook K&S; Abrams, William; Pada, Roxane Cc: Skyhook_Service Subject: RE: Skyhook v. Google: Lars Fjeldsoe-Nielsen's Responses and Objections and other discovery issues

Azra – Thanks for your message. In the interim between my message and your response, the schedule today became filled up, so we are not available this afternoon. We propose tomorrow afternoon at the same time (4 pm Eastern). Please let us know if that works for you; if so, I’ll circulate a calendar notice with dial-in information. Further, I will respond in writing to some of your points, and provide you final positions on some of the outstanding issues and confirm some dates, later this evening, in advance of the meet and confer.
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4
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8

Tom,
We
expect
to
complete
Mr.
Fjeldsoe-­‐Nielsen's
production
and
update
privilege
and
redaction
log
entries
that
involve him
by
Monday,
June
17.
Thus,
Mr.
Fjeldsoe-­‐Nielsen's
deposition
can
and
will
proceed
on
July
2
unless
the
Court responds
to
our
joint
request
for
a
hearing
on
July
2.
As
we
already
said,
we
will
give
you
an
alternative
date
if
and when
the
Court
accepts
the
parties'
proposed
date.
With
respect
to
the
remainder
of
the
Jed
Rice
privileged
or
redacted
documents,
I
have
told
Google
weeks
ago
that we
are
working
to
complete
that
re-­‐review
by
July
1.
Google
had
no
objection
to
that
at
the
time,
and
you
cannot now
fabricate
new
deadlines
and
threaten
a
motion
to
compel
this
Monday
if
we
do
not
complete
that
review
by Monday.
Further,
Google's
rhetoric
and
requests
stand
in
sharp
contrast
with
what
it
itself
is
agreeing
to
do
in
this
case,
which makes
them
all
that
much
more
unreasonable.
I
have
asked
you
many
times
to
confirm
that
you
will
complete
the relevant
productions
two
weeks
before
the
depositions—as
we
are
doing
with
Mr.
Fjeldsoe-­‐Nielsen—but
you
have not
so
agreed.
We
have
met
and
conferred
on
Skyhook's
Third
Set
of
Document
Requests
over
several
sessions,
and you
were
not
prepared
at
the
last
telephonic
meet
and
confer
to
give
us
Google's
final
positions
on
those
requests.
You
did
not
have
Google's
response
regarding
search
terms
Skyhook
proposed
nor
about
Skyhook's
request
for
Mr. Brin's
documents.
You
did
not
have
any
deposition
dates
to
offer
but
one.
Please
be
prepared
to
discuss
each
of these
issues
on
Monday
and
provide
deposition
dates
for
the
remaining
deponents,
or
provide
a
written
response
in advance.
I
am
available
at
4
PM
Eastern
on
Monday.
If
that
time
works,
I
will
circulate
a
meeting
invitation
and
a dial-­‐in.
We
can
discuss
Bain
Capital's
responses
to
Google's
subpoena
at
the
same
time.
On
that
issue,
you
are
are misstating
our
discussion.
I
have
asked
you
to
explain
why
Google
is
seeking
information
from
third
parties
that
is burdensome
and
overbroad,
such
as
"documents
concerning
companies
that
compete
with
Skyhook"
or
"documents defining
or
describing
the
market
in
which
Skyhook
products
compete,
and
the
market
share
of
Skyhook
or
its competitors."
And
then
I
pointed
out
that
Google
has
served
the
very
same
subpoena
on
all
third
parties,
and
it appears
no
third
party
has
given
you
production
on
your
burdensome
and
overbroad
requests
such
as
the
ones
I pointed
to.
Please
be
prepared
to
discuss
how
exactly
you
would
expect
a
third
party
to
search
for
and
find documents
on
these
and
the
other
requests
on
which
Bain
Capital
has
offered
at
least
three
times
so
far
to
confer, but
Google
was
not
prepared
to
do
so.
Finally,
we
are
assuming
that
the
dates
for
Mr.
Zelinka's
and
Skyhook's
proposed
depositions
work
for
Google
(given that
they
are
scheduled
for
dates
Mr.
Zelinka
and
Google's
counsel
are
available),
but
to
avoid
any
doubt,
please

Azra – I’m writing to follow up on the below message and Google’s multiple, longstanding requests that Skyhook produce documents improperly withheld under a claim of privilege and produce new privilege logs for any documents Skyhook continues to withhold. First, below, Google agreed to depose Mr. Fjeldsoe-Nielsen on July 2 on the conditions that by June 17, (1) Mr. Fjeldsoe-Nielsen produces documents; and (2) Skyhook completes its rereview of its privilege and redaction logs and produces documents and a new log with sufficient information. We have not received any response confirming that Skyhook will make those productions by June 17. In addition, the parties requested a status conference/hearing with the Court on July 2, on the condition that Skyhook provide alternate dates close to July 2 for Mr. Fjeldsoe-Nielsen’s deposition, if the Court agrees to hold the status conference/hearing on that date. Skyhook has not provided those alternate dates. Please provide alternate dates for Mr. Fjeldsoe-Nielsen, in the event that the Court agrees to July 2, and please confirm that Mr. Fjeldsoe-Nielsen’s documents will be produced by June 17. Second, with respect to the privilege log and purportedly privileged documents, Google has been requesting since April 9 that Skyhook produce documents withheld under a claim of privilege relating to Jed Rice. The parties exchanged multiple messages and discussed the issue in more than one meet-and-confer. By May 16, Skyhook had promised to re-review all
Page
6
of
8

Case 1:10-cv-11571-RWZ Document 196-2 Filed 07/01/13 Page 8 of 9

documents withheld on a claim of privilege relating to Mr. Rice, but would not commit to a date certain by which it would produce previously withheld documents or provide new privilege and redaction logs. Google has made plain, multiple times, and most recently below, that the privileged documents must be produced sufficiently in advance of depositions beginning to allow for meaningful review. Skyhook must confirm by tomorrow, June 14, that it will produce formerly withheld documents and new privilege and redaction logs on June 17, or Google will be forced to file a motion to compel on Monday. Let me know if you have any questions. Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134 tlundin@kslaw.com

Azra – Thanks for your message. We remain available to depose Mr. Fjeldsoe-Nielsen on July 2, but that date will work only if by June 17 (1) Mr. Fjeldsoe-Nielsen produces documents; and (2) Skyhook completes its re-review of its privilege and redaction logs, which Google has been requesting since at least April 9, for at least those entries involving Mr. Fjeldsoe-Nielsen (approximately 60-70 entries), and provides a new log with sufficient information to assess the privilege claims or produces previously withheld nonprivileged documents, as Skyhook has promised to provide since May 16. Please let us know this week whether Skyhook and Mr. Fjeldsoe-Nielsen will do the foregoing, so that we can go forward with his deposition on July 2. Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134
Page
7
of
8

Tom,
Please
see
attached
Mr.
Fjeldsoe-­‐Nielsen's
Responses
and
Objections
to
Google's
Subpoena.
Mr.
Fjeldsoe-­‐Nielsen
is available
for
his
deposition
on
July
2.
Please
confirm
your
availability
early
next
week.
Thank
you.
Best,
Azra

Dear
Azra-­‐
We
have
discussed
at
length
since
February
that
Mr.
Brin
is
not
relevant
to
any
aspect
of
Skyhook’s
case.
Skyhook noGced
Mr.
Brin’s
deposiGon
without
any
basis
other
than
to
harass
one
of
the
highest
ranking
execuGves
and co-­‐founder
of
Google.
Google
repeatedly
asked
Skyhook
to
explain
Mr.
Brin’s
relevance
to
Skyhook’s
patent
case.
Skyhook’s
response
provided
no
basis:
“We
understand
that
Mr.
Brin
was
at
the
Macworld
event
in
January
2008
at
which
Apple
announced
that
it was
using
Skyhook's
locaGon
technology
in
its
iPhone
and
that
Mr.
Brin
had
discussions
with
Apple representaGves
about
that
announcement
and
Google's
displeasure
with
it.”
Skyhook
has
never
provided
any
basis
for
its
asserGon
that
Mr.
Brin
has
any
connecGon
to
this
case.
We
pointed out
that
roughly
50,000
persons
a1ended
Macworld
in
2008
with
Mr.
Brin.
Nevertheless,
Google
searched
Mr. Brin’s
emails
for
the
terms
“Skyhook,”
“ Ted
Morgan,”
and
“Macworld.”
No
documents
indicate
that
Mr.
Brin
has any
personal
knowledge
of
any
issue
relevant
to
the
claims
or
defenses
in
this
acGon.
Google
has
conducted
a reasonable
search
for
documents
from
Mr.
Brin,
determined
that
the
resulGng
documents
are
not
relevant
and
has no
obligaGon
to
conduct
any
addiGonal
searches.
We
will
bring
a
moGon
for
protecGve
order
and
seek
sancGons
if Skyhook
persists
in
this
harassment.
Regarding
the
ESI
Search
terms,
Google
responded
on
Saturday.
In
case
you
did
not
receive
it,
I
am
a1aching

1 of 6

Case 1:10-cv-11571-RWZ Document 196-3 Filed 07/01/13 Page 3 of 8
Google’s
response
that
explains
the
large
cost
and
burden
involved
in
reviewing
and
producing
documents
that would
result
from
Skyhook’s
over-­‐broad
search
strings.
Regarding
deposiGons,
Google
conﬁrms
the
availability
of
Mike
Lockwood
to
appear
on
July
23.
As
we
discussed
during
our
meet
and
confer,
Skyhook
deposed
Mr.
Brady
for
two
days
in
the
state
court
acGon.
Mr. Brady
explained
in
his
deposiGon
that
he
manages
partner
relaGonships.
Other
than
asserGng
that
the
state
court case
is
diﬀerent
than
the
current
case,
Skyhook
has
not
provided
an
explanaGon
why
Mr.
Brady
should
be
deposed again
and
in
this
patent
case.
Please
explain
what
knowledge
Skyhook
believes
Mr.
Brady
has
that
is
speciﬁc
to
the issues
of
this
patent
case
that
Skyhook
did
not
already
cover
in
its
two
day
deposiGon
of
Mr.
Brady.
Mr.
Zelinka
will
be
available
for
his
deposiGon
on
July
10.
Google
disagrees
that
it
is
under
any
obligaGon
to produce
Mr.
Zelinka’s
documents,
solely
because
he
will
be
one
of
Google’s
technical
30(b)(6)
witnesses.
Skyhook has
not
provided
any
authority
or
caselaw
to
the
contrary.
As
we
discussed,
Google
has
produced
millions
of
pages of
documents
including
Google’s
source
code
that
explains
the
operaGon
of
Google’s
product.
In
view
of
this, Skyhook
has
not
provided
any
reason
why
Mr.
Zelinka’s
documents
are
needed
above-­‐and-­‐beyond
Google’s thorough
producGon
of
technical
documents.
Regarding
RFPs
254
and
255
which
both
ask
for
policies
regarding
third
party
patents,
acer
a
reasonable
search, Google
has
not
located
any
such
policies.
With
regard
to
Skyhook’s
requests
for
Tracbeam
discovery,
Skyhook
has
not
explained
the
relevance
of
Google’s discovery
responses
in
Tracbeam.
The
patents
in
the
Tracbeam
case
are
not
related
to
the
patents
asserted
by Skyhook
and
accordingly,
Google
should
not
bear
the
cost
and
burden
of
producing
the
transcripts
and
discovery responses
that
are
not
relevant
to
this
acGon.
If
you
have
any
quesGons,
please
let
me
know.
Best
regards,

Dear Sanjeet,
I write to follow up on our latest June 20 meet and confer, in particular since Skyhook did not receive the follow-up responses on several of these issues on Friday, June 21, which you had committed to provide. On each of the issues addressed below (except on Mr. Zelinka's documents), unless by close of business on Tuesday Google agrees to produce documents or provide conﬁrmations Skyhook has been seeking for weeks

2 of 6

Case 1:10-cv-11571-RWZ Document 196-3 Filed 07/01/13 Page 4 of 8
now, Skyhook will move to compel production.
Individual Depositions Skyhook Noticed on May 23: Google's explanation that its in-house counsel has been unable to get availability from any of the seven deponents Skyhook noticed—for a whole month—is simply unacceptable. Google is not complying with its discovery obligations, and unless Google provides proposed dates for each of the noticed deponents by close of business on Tuesday, Skyhook will move to compel those depositions. Separately, please get back to us on our proposal that the parties forgo subpoenas for party witnesses and agree to produce non-duplicative relevant documents from those witnesses' possession.
Mr. Brin's Documents: Absent Google's response to our requests, speciﬁcally identiﬁed in my email attached below and discussed further at our June 20 meet and confer, by close of business on Tuesday, Skyhook will move to compel production of Mr. Brin's documents.
ESI Search Terms: Google has not yet responded to Skyhook's June 3 request to run additional ESI searches and produce responsive documents, and Skyhook will move to compel production absent a response by close of business on Tuesday.
Skyhook's Third Set of Document Requests: Skyhook pointed out during our meet and confer that it is still awaiting Google's responses on RFPs 199 (licenses and negotiations with OEMs) and 304 (how Google uses location data in its advertising) and Google has not yet provided a response.
Further, on RPFs 254 (policies regarding studies of Google's patents) and 255 (policies regarding comparisons of Google's products with third-party patents), to the extent Google maintains that documents responsive to these RPFs are privileged, Google must identify such documents on its privilege log.
Finally, with respect to Trackbeam litigation documents (RFP 303), Google has agreed to produce (1) documents produced in Tracbeam that have not been produced in this action and (2) transcripts of depositions taken in the Tracbeam action for witnesses who are common to both actions. Skyhook requested conﬁrmation that Google will include its discovery responses provided in that litigation as well as all deposition transcripts (including corporate depositions). To the extent that Google deems certain of the witnesses somehow irrelevant to this litigation, Skyhook has asked that Google identify those witnesses to Skyhook. Given that these follow-up requests are all within the scope of our late May discussions, Skyhook will move to compel production absent Google's agreement to produce documents or explain its belief that it has already produced responsive documents by close of business on Tuesday.
Mr. Zelinka's Documents: Google has identiﬁed Mr. Zelinka as its corporate deponent on core technical topics, indeed he is the sole corporate deponent that Google has agreed to make available for deposition to date. You explained in the meet and confer that Google identiﬁed him as the corporate witness for these topics because he has the most comprehensive institutional knowledge among Google's employees currently working on the features of the accused products relevant to the topics on which he has been identiﬁed. Google also identiﬁed Mr. Zelinka in its January 30, 2013 second supplemental initial disclosures as one of only eleven Google employees knowledgeable about the issues in this litigation, and moreover, as one of only half-dozen employees

3 of 6

Case 1:10-cv-11571-RWZ Document 196-3 Filed 07/01/13 Page 5 of 8
knowledgeable about the operation of the accused products. However, Google has not collected, and has not produced, Mr. Zelinka's documents in this litigation and its position is that it will only produce Mr. Zelinka's documents if Skyhook can identify documents in Mr. Zelinka's ﬁles that it has not received from other custodians. This position is clearly improper because Google, not Skyhook, has access to Mr. Zelinka's documents, and given the importance Google has assigned to Mr. Zelinka's knowledge of the operation of the accused products by virtue of his designation as a corporate witness. Skyhook will proceed with Mr. Zelinka's deposition on July 10, reserving its right to seek production of Mr. Zelinka's documents after the deposition and to reopen or continue his deposition after Google produces his documents.
Thank you.
Best, Azra

From:
Azra
Hadzimehmedovic
<azra@tensegritylawgroup.com> Date:
Wednesday,
June
19,
2013
1:49
PM To:
"Lundin,
Tom"
<TLundin@KSLAW.com>,
"dl.zzmgoogleskyhookext@bingham.com" <dl.zzmgoogleskyhookext@bingham.com>,
Google/Skyhook
K&S
<Google_SkyhookK&S@KSLAW.com>,
"Abrams, William"
<BAbrams@KSLAW.com>,
"Pada,
Roxane"
<RPada@KSLAW.com> Cc:
Skyhook_Service
<Skyhook_Service@tensegritylawgroup.com> Subject:
Re:
Skyhook
v.
Google:
Lars
Fjeldsoe-­‐Nielsen's
Responses
and
ObjecGons
and
other
discovery
issues
Tom, thank you for your responses. I will address several of them in this email in the hopes of streamlining our telephonic meet and confer.
First, Google has selected Mr. Zelinka as a corporate representative on some of the core technical deposition topics, yet has not named him as a custodian nor produced his documents. Under the circumstances, Mr. Zelinka's responsive documents clearly should be produced. Please conﬁrm that you will produce Mr. Zelinka's responsive documents at least two weeks prior to his deposition.
Second, it is unacceptable that nearly one month after Skyhook noticed seven Google's employees for their individual depositions, Google has not responded with a proposed date for even one of those deponents. Google appears intent on delaying the resolution of this most straightforward issue, forcing motion practice

4 of 6

Case 1:10-cv-11571-RWZ Document 196-3 Filed 07/01/13 Page 6 of 8
knowing that it will take time for the opposing briefs to get ﬁled, only so that Google will then—on the eve of the court's hearing—propose deposition dates. This very thing just happened with Google's interrogatory responses it had been refusing to provide until Skyhook ﬁled its motion to compel. It is both unreasonable and unfair for Google to be delaying Skyhook's case in this manner and wasting both Skyhook's and the Court's resources on such issues.
Third, Skyhook's deposition notices for Messrs. Lee and Brady in this case are wholly appropriate, and Google's arguments about overlap in those witnesses' depositions between this and the state case are unavailing. Skyhook's patent infringement case is separate and different from its state tortious interference case. The technical, willfulness, and the damages issues in the patent case are speciﬁc to this case. Further, Google cannot legitimately argue that Mr. Lee's and Mr. Brady's state-case depositions that took place before their custodian productions in this case even commenced and before Google produced the bulk of its production in this case are sufﬁcient discovery of those witnesses for this case. We repeat our request for an immediate identiﬁcation of their availability as well as the availability of all individual witnesses Skyhook has noticed nearly a month ago.
Finally, with respect to Skyhook's request for Mr. Brin's documents, Skyhook requested that Google search the following search strings:

i. Skyhook ii. (Ted or Edward) w/3 Morgan iii. (Mike or Michael) w/3 Shean iv. (“MacWorld” or “Mac World”) and (Apple or Jobs or location or driv* or beacons or triangulat*) v. “Location-based services” or LBS or GLS
vi. (“Location” or Wi-Fi or WiFi or Wi?Fi or wireless or WLAN) and (advert* or revenue or value)
Please explain why Google refuses to search Mr. Brin's documents for search strings v and vi. Please let us know how many documents each of our individual requested search strings yielded. (To the extent that the MacWorld search you ran yielded a large number of responsive documents, please let us know how many documents are responsive to our proposed search string no. iv, which is signiﬁcantly narrower.) And please conﬁrm that Google is refusing to produce the documents that those six search strings yield and expects Skyhook and the Court to rely on Google's representation that although responsive documents were found, not one is relevant.
I have already circulated a meeting invite and a dial-in for Sanjeet for our meet and confer tomorrow at 4 PM Eastern.
Thank you.
Best, Azra

RFP 315: Google does not believe that it has any responsive documents. Google is confirming again and agrees to produce any such documents that exist.

King & Spalding Confidentiality Notice: This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message.

Subject: Skyhook
v.
Google
-­‐
ESI Date: Saturday,
June
22,
2013
6:07:05
PM
Pacific
Daylight
Time From: To: CC:
Azra -I'm writing to follow up on the conversation between you and Sanj on Thursday. As we have explained previously, Google has been diligently analyzing both Skyhook's requests to 1) amend the search terms used in the "Skyhook I" action using the amended search terms that Skyhook proposed; and 2) add new search terms that Skyhook asserts are relevant to the "Skyhook II" action. The analysis of Skyhook's proposals is now complete, and the results show that it would be extremely costly and unduly burdensome to gather and produce documents resulting from Skyhook's proposed search terms. The results of the analysis show the following estimated costs and times required: A) Approximately $1,225,000 and 38 days to review approximately 644,000 documents in response to Nos. 1 & 2 above; B) Approximately $633,000 and 19 days to review approximately 318,000 documents for only No. 1 above; and C) Approximately $1,072,000 and 33 days to review approximately 560,000 documents for only No. 2 above. The foregoing would be unquestionably unduly burdensome, even had Google not already produced more than 2.7 million pages of documents in the Skyhook I litigation, and made the key technical information -the source code of the accused instrumentality in both actions -- available many years ago. Particularly in light of those facts, as well as the plainly overburdensome and over broad nature of Skyhook's proposals, Google request that Skyhook provide a more reasonable set of search strings (including, by way of example only, fewer terms, with closer proximities, and with narrower Boolean connectors) that are more narrowly focused to target documents that Skyhook contends that it needs to prove the claims asserted in the former Skyhook II case--that would not be duplicative of the information found in the vast volume of documents already produced. Regards, Tom Lundin Jr. King & Spalding LLP 1180 Peachtree St. NE Atlanta, GA 30309-3521 404-572-2808 Fax: 404-572-5134 tlundin@kslaw.com

Dear
Bill,
in
the
attached
notice,
Skyhook
is
requesting
Sergey
Brin's
deposition
on
February
28,
2013.
Please
produce
Mr.
Brin's
emails
relating
to
Skyhook,
development
of
Google's
location-­‐based
services,
the
value
of
location
data
to
Google,
and
any
related
analyses
or
valuations.
These
documents
are
responsive
to
at
least
the
following
Skyhook's
RFPs:
2-­‐6,
32,
39,
156,
and
159-­‐161.
Please
complete
this
production
or
confirm
completion
of
production
of
Mr.
Brin's
email
by
no
later
than
February
20,
2013.
AZRA
HADZIMEHMEDOVIC

Azra Hadzimehmedovic <azra@tensegritylawgroup.com> Re: Skyhook v. Google -- No. 1:10-cv-11571-RWZ March 6, 2013 2:09 PM Dear
Bill, We
understand
that
Mr.
Brin
was
at
the
Macworld
event
in
January
2008
at
which
Apple
announced
that
it
was
using
Skyhook's
location
technology
in
its
iPhone
and
that
Mr.
Brin
had
discussions
with
Apple
representatives
about
that
announcement
and
Google's
displeasure
with
it.
He
is
uniquely
able
to
discuss
his
reactions
to
the
announcement,
and
his
subsequent
conversations
regarding
it,
as
well
as
any
actions
taken
or
policies
adopted
by
Google
as
a
consequence
thereof.
You
have
confirmed
that
Google
has
not
collected
any
of
Mr.
Brin's
own
documents
or
emails
and
that
Google's
counsel
has
not
even
spoken
with
Mr.
Brin
to
determine
the
extent
of
relevant
and
non-­‐cumulative
information
he
possesses.
We
also
believe
that
Google
has
failed
to
collect
any
documents
from
its
executives.
Nonetheless,
based
on
our
review
of
Google's
production,
for
example,
Google's
Location-­‐Based
Services
meeting
notes
reveal
that
both
Mr.
Brin
and
Mr.
Page
received
briefings
about
the
development
of
Google's
Location-­‐Based
Services,
and
that
they
participated
in
product
reviews
and
"sales
readiness"
evaluations.
Further,
among
those
briefings,
Mr.
Brin
appears
to
have
received
briefings
about
Google's
effort
to
place
Google's
location
services
in
the
iPhone
(instead
of
Skyhook
or
other
third
parties)
so
that
Google
could
collect
the
user's
WiFi
information.
Therefore,
Mr.
Brin
has
unique
first-­‐ hand
knowledge
about
the
development
of
the
accused
products
and
the
strategic
value
of
those
services
to
Google.
Further,
Google
cannot
deny
that
its
executives,
both
Mr.
Page
and
Mr.
Brin,
have
placed
a
great
value
on
Google's
location
services
and
the
extraordinary
value
Google
receives
from
location-­‐based
data.
They
can
speak
to
that
value
from
their
unique
position
at
the
helm
of
the
company
and
their
judgment
and
perspective
on
the
issue
cannot
be
replaced
or
supplanted
by
other
witnesses.
And
based
on
our
understanding,
Google's
representation
that
Mr.
Brin
was
not
keenly
aware
of
the
development
of
the
location-­‐based
services
products
is
incorrect.
We
have
seen
at
least
one
email
string
in
which
Mr.
Brin
suggests
to
Google's
engineers
how
to
fix
a
bug
related
to
Google's
location
services‹a
thread
that
appears
to
have
been
prompted
because
Mr.
Brin's
own
location
itself
was
buggy:
"Sergey's
location
ping
pongs
around
at
night.
.
.
."
Mr.
Brin
can
speak
to
the
accused
products
from
the
perspective
of
an
executive
who
understands
the
accused
technology
and
cares
about
its
inner
workings
as
well
as
its
strategic
importance
to
Google. Thus,
Skyhook
believes
that
Mr.
Brin
has
unique
and
non-­‐repetitive
knowledge
regarding
willful
infringement
and
damages
issues.
As
we
are
sure
you
are
aware,
Google
has
recently
been
faced
with
a
similar
issue
in
its
Oracle
case,
where
it
tried
to
resist
providing
Mr.
Page's
deposition.
Just
like
in
this
case,
Google
argued
that
its
founder
did
not
have
first-­‐hand
knowledge
of
the
issues
relevant
to
willful
infringement,
but
the
Court
did
not
believe
Google's
excuses.
Although
the
Court
understood
that
Mr.
Page
may
not
have
even
participated
directly
in
the
negotiations
at
issue
in
that
case,
the
Court
held
that
it
was
"highly
likely
that
Mr.
Page
participated
in
decision-­‐making
regarding
[those]
negotiations."
Oracle
Am.,
Inc.
v.
Google,
Inc.,
2011
U.S.
Dist.
LEXIS
79465,
at
*6-­‐7
(N.D.
Cal.
July
21,
2011).
We
also
note
that
so
far
Google
has
only
made
unfounded
claims
of
harassment,
but
Google
has
not
denied
Mr.
Brin's
knowledge
on
any
the
issues
Skyhook
has
raised.
Google's
position
is
especially
troubling
given
your
statements
during
our
Rule
26
conference
that
Skyhook's
own
CEO
was
a
per
se
non-­‐cumulative
and
highly
relevant
deponent
despite
the
undisputed
fact
that
he
was
not
even
present
at
Skyhook
until
very
recently
and
was
not
capable
of
having
percipient
knowledge
of
any
of
the
relevant
background
events
in
which
Mr.
Brin,
by
contrast,
was
personally
and
instrumentally
involved.
Thus,
we
respectfully
repeat
our
request
that
you
in
fact
speak
with
Mr.
Brin
about
his
knowledge
related
to
the
activities
we
have
identified.
And
we
request
that
Google
tells
us‹specifically‹why
it
believes
other
Google
employees
are
the
more
appropriate
deponents
than
Mr.
Brin
on
the
specific
topics
we
have

From:
<Abrams>,
William
<BAbrams@KSLAW.com> Date:
Monday,
February
25,
2013
10:55
AM To:
Azra
Hadzimehmedovic
<azra@tensegritylawgroup.com> Cc:
Aaron
Nathan
<aaron.nathan@tensegritylawgroup.com>,
Skyhook_Service
<Skyhook_Service@tensegritylawgroup.com>,
Douglas
Tillberg
<dtillberg@gtmllp.com>,
Google/Skyhook
K&S
<Google_SkyhookK&S@KSLAW.com>,
"Evans,
Laura"
<LEvans@irell.com>,
"Lu,
Sam
(SLu@irell.com)"
<SLu@irell.com>,
"Lundin,
Tom"
<TLundin@KSLAW.com> Subject:
RE:
Skyhook
v.
Google
-­‐-­‐
No.
1:10-­‐cv-­‐11571-­‐RWZ
Dear
Azra
-­‐ You
have
not
provided
any
support
for
your
"understanding
...
that
Mr.
Brin
is
knowledgeable
on
these
topics
and
could
offer
testimony
and
perspective
that
is
not
directly
available
to
Google's
other
witnesses."
What
is
the
basis
for
this
understanding?
We've
asked
you
several
times
for
this,
but
you
have
not
provided
any
evidence
to
support
it. Mr.
Brin
is
a
founder
and
senior
leader
of
one
of
the
largest
companies
in
the
world.
Skyhook
bears
the
initial
burden
of
showing
that
a
person
in
Mr.
Brin's
position
has
unique
knowledge
on
relevant
subject
matter,
i.e.,
not
just
his
own
perspective
on
information
available
from
others
or
through
other
means.
In
addition,
Skyhook
must
have
actually
sought
the
information
in
another,
less
burdensome
way
before
seeking
this
deposition
and
establishing
that
it
is
necessary. Skyhook
has
not
met
any
of
its
burdens,
and
there
is
no
basis
for
imposing
on
Mr.
Brin
given
the
lack
of
any
showing
by
Skyhook
as
we
have
stated.
The
deposition
notice
appears
tactical
and
intended
to
harass
Mr.
Brin
and
Google,
particularly
given
that
the
notice
is
served
at
the
beginning
of
taking
depositions
in
the
case,
before
Skyhook
has
examined
any
witnesses
regarding
relevant
subject
matter.
We
are
prepared
to
seek
a
protective
order,
and
sanctions,
if
Skyhook
does
not
withdraw
the
deposition
notice
for
Mr.
Brin. Bill

Tom, Thank
you
for
following
up
on
our
conversation
on
Friday.
Yes,
the
parties
have
agreed
to
reschedule
the
currently
noticed
depositions
and
have
also
agreed
not
to
wait
for
the
Court
to
hold
the
hearing
regarding
Google's
motion
to
consolidate,
but
to
proceed
in
the
meantime
to
work
on
rescheduling
the
previously
noticed
depositions. With
respect
to
Skyhook's
requests
for
Mr.
Brin's
deposition
and
production
of
relevant
email,
Google
confirmed
that
it
has
not
in
fact
spoken
to
Mr.
Brin
to
determine
whether
he
has
information
relevant
to
Skyhook's
case.
Skyhook
therefore
requests
that
Google
specifically
confirm
with
Mr.
Brin
whether
he
has
relevant
knowledge
in
the
following
areas: (1)
attendance
and
participation
at
Macworld
2008,
including
discussions
relating
to
Skyhook's
or
Google's
location
technology; (2)
discussions
with
Apple
regarding
Google's
location-­‐based
services; (3)
direction
and
management
of
the
development
of
Google's
location-­‐based
services; (4)
value
of
location-­‐based
data
to
Google; (5)
knowledge
of
and
participation
in
discussions
relating
to
Skyhook's
location
technology
and
Google's
valuation
and
knowledge
about
that
technology;
and (6)
decisions/discussions
regarding
the
Motorola
and
Samsung
deals
and/or
potential
deals
with
Skyhook
relating
to
location
technology. If
Mr.
Brin
is
willing
to
submit
a
declaration
that
he
has
not
participated
in
the
activities
outlined
above
and
does
not
have
any
firsthand
knowledge
in
these
areas,
then
we
would
be
willing
to
consider
withdrawing
our
deposition
notice
and
request
for
Mr.
Brin's
email.
Our
understanding,
however,
is
that
Mr.
Brin
is
knowledgeable
on
these
topics
and
could
offer
testimony
and
perspective
that
is
not
directly
available
to
Google's
other
witnesses.
Further,
unless
Mr.
Brin
is
willing
to
declare
under
oath
that
he
in
fact
has
no
relevant
knowledge
related
to
Skyhook's
case,
Google's
objection
to
conducting
targeted
searches
of
his
email
on
the
limited
topics
Skyhook
has
identified
is
improper. Best,
Azra
AZRA
HADZIMEHMEDOVIC

Case 1:10-cv-11571-RWZ Document 196-5 Filed 07/01/13 Page 5 of 5

TENSEGRITY
LAW
GROUP
LLP 555
Twin
Dolphin
Drive,
Suite
360 Redwood
Shores,
CA
94065 650-­‐802-­‐6055
(phone) 202-­‐321-­‐3879
(mobile) 650-­‐802-­‐6001
(fax) On
2/15/13
5:41
PM,
"Lundin,
Tom"
<TLundin@KSLAW.com>
wrote: Azra
-­‐-­‐ I'm
confirming
our
conversation
earlier
today.
We
agreed
that,
with
respect
to
the
depositions
noticed
by
each
party
thus
far,
neither
party
has
the
expectation
that
the
depositions
will
occur
on
the
dates
set
forth
in
the
notices/subpoenas.
With
one
exception,
noted
below,
the
parties
will
continue
to
work
on
identifying
dates
for
the
noticed
witnesses
and
will
communicate
further
on
potential
rescheduled
dates. The
exception
noted
above
applies
to
the
deposition
notice
Skyhook
issued
for
Mr.
Brin.
Although
we
did
not
discuss
the
Brin
notice
today,
it
was
discussed
during
the
Rule
26(f)
conference
on
Monday,
when
Google
reiterated
its
previously
emailed
objection
and
request
that
Skyhook
withdraw
the
Brin
notice.
During
the
Rule
26(f)
conference
you
proposed
sending
us
some
information
concerning
Skyhook's
desire
to
depose
Mr.
Brin.
We
said
that
we
would
review
the
information,
but
did
not
withdraw
our
request
that
the
notice
be
withdrawn.
Please
let
us
know
whether
Skyhook
will
agree
to
withdraw
the
Brin
notice,
so
that
we
can
determine
whether
Google
needs
to
move
for
a
protective
order. Please
don't
hesitate
to
call
with
any
questions.
Have
a
good
weekend. Regards, TCL King
&
Spalding
Confidentiality
Notice: This
message
is
being
sent
by
or
on
behalf
of
a
lawyer.
It
is
intended
exclusively
for
the
individual
or
entity
to
which
it
is
addressed.
This
communication
may
contain
information
that
is
proprietary,
privileged
or
confidential
or
otherwise
legally
exempt
from
disclosure.
If
you
are
not
the
named
addressee,
you
are
not
authorized
to
read,
print,
retain,
copy
or
disseminate
this
message
or
any
part
of
it.
If
you
have
received
this
message
in
error,
please
notify
the
sender
immediately
by
e-­‐mail
and
delete
all
copies
of
the
message.

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 1 of 145

EXHIBIT 6

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 2 of 145

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS SKYHOOK WIRELESS, INC., Plaintiff and Counterclaim-Defendant, v. GOOGLE INC., Defendant and Counterclaimant. ) ) ) ) ) ) ) ) ) ) ) ) )

Case No. 1:10-cv-11571-RWZ Case No. 1:13-cv-10153-RWZ

GOOGLE INC.’S OBJECTIONS AND RESPONSES TO SKYHOOK WIRELESS, INC.’S THIRD SET OF REQUESTS FOR PRODUCTION Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, defendant and counterclaimant Google Inc. (“Google”) hereby responds and objects to the Third Set Of Requests For Production Of Documents And Things (Nos. 176-316) (the “Third Requests”) served by plaintiff and counterclaim-defendant Skyhook Wireless, Inc. (“Skyhook”). GENERAL OBJECTIONS AND RESPONSES Google objects to the Third Requests as unreasonably duplicative and cumulative of Skyhook Wireless, Inc.'s First Set Of Requests For Production To Google Inc. (the “First Requests”) and Skyhook Wireless, Inc.'s Second Set Of Requests For Production To Google Inc. (the “Second Requests”), to the extent that the requests are directed to the ‘988, ‘694, ‘897, and ‘245 patents. During discovery in these cases, Google has produced more than 2.5 million pages of documents (1) collected from a large number of technical document repositories, i.e., internal sites, wikis, and dashboards, and (2) from agreed-upon custodians – and additional custodians demanded by Skyhook – that were responsive to search terms relevant to the case. Google also has made available for inspection source code relevant to the Accused Products since October

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 3 of 145

2011. These productions contain documents and information relevant to the claims and defenses in Skyhook Wireless, Inc. v. Google Inc., No. 1:10-cv-11571-RWZ (D. Mass.) filed September 15, 2010 (“Skyhook I”), as well the claims and defenses in Skyhook Wireless, Inc. v. Google Inc., No. 1:10-cv-10153-RWZ (D. Mass.) (“Skyhook II”). Accordingly, Google objects to Skyhook’s Third Requests as unduly burdensome and unreasonably duplicative to the extent Google has already produced information responsive to the Skyhook’s Third Requests. Google hereby incorporates by reference as if fully set forth herein its General Objections stated in the First Requests and Second Requests, and its objections and responses to individual requests stated in the First Requests and Second Requests, to the extent that those requests are duplicated by requests in the Third Requests, and limits its responses herein to the patents named in Skyhook II. Google further asserts the General Objections, Objections To Definitions, and Objections To Instructions stated in Exhibit A hereto. OBJECTIONS AND RESPONSES TO SPECIFIC REQUESTS FOR PRODUCTION Subject to and without waiving the foregoing and to the objections stated in Exhibit A, Google responds to each request for production as follows: REQUEST FOR PRODUCTION NO. 176: All Documents Relating To the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 176: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the

2

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 4 of 145

attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 1, and seeks materials previously produced by Google. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 177: All Documents Relating To any of the Skyhook Patent Inventors. RESPONSE TO REQUEST FOR PRODUCTION NO. 177: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 2, and seeks materials previously produced by Google. 3

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 5 of 145

Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 178: Documents, including all source code, sufficient to show the structure, function, operation, design, testing, and development, of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 178: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 5, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 5. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, including without limitation source code, as have been located after a reasonable and good faith search that are responsive to this Request.

4

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 6 of 145

REQUEST FOR PRODUCTION NO. 179: Documents, including all source code, sufficient to show the structure, function, operation, design, testing, and development of Google Location Service. RESPONSE TO REQUEST FOR PRODUCTION NO. 179: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location Services,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 6, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 6. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 180: Documents, including all source code, sufficient to show the structure, function, operation, design, testing, and development of Google’s Network Location Provider. RESPONSE TO REQUEST FOR PRODUCTION NO. 180: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and

5

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 7 of 145

defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 7, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 7. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 181: All Documents Relating To the structure, function, operation, design, development, creation, testing, optimization, use, and storage of, and collection and processing of data for the Google Wi-Fi Location Database, including an electronic version of Google’s Wi-Fi Location database, including access to Google’s database of raw data. RESPONSE TO REQUEST FOR PRODUCTION NO. 181: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Wi-Fi Location Database” and “Google’s database of raw data,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine.

6

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 8 of 145

Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 8, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 8. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request as it relates to the asserted patents in Skyhook I; and Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 182: All Documents Relating To the structure, function, and operation of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database with respect to their use to determine the location of a Wi-Fi-enabled device or a device having a Wi-Fi radio.

7

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 9 of 145

RESPONSE TO REQUEST FOR PRODUCTION NO. 182: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, , including without limitation in its use of the terms “Google Location,” “Google Location Services,” “Google Wi-Fi Location Database,” and “Wi-Fi enabled device,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 9, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 9. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 183: All Documents Relating To the manner in which Google Location determines which location technique to use in estimating the location of a Wi-Fi enabled device, e.g., Cell ID, cell tower triangulation, Wi-Fi, and GPS. 8

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 10 of 145

RESPONSE TO REQUEST FOR PRODUCTION NO. 183: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location” and “Wi-Fi enabled device,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 9, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 9. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 184: All Documents Relating To the accuracy or estimated accuracy of Google’s Wi-Fi location calculations, including the accuracy or estimated accuracy of location estimates of Wi-Fi enabled mobile devices and Wi-Fi access points.

9

Case 1:10-cv-11571-RWZ Document 196-6 Filed 07/01/13 Page 11 of 145

RESPONSE TO REQUEST FOR PRODUCTION NO. 184: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, , including without limitation in its use of the terms “accuracy,” “estimated accuracy,” and “Wi-Fi enabled mobile devices,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 8 and 9, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 8 and 9. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 185: All Documents Relating to the comparative accuracy of location estimations based on Google’s Wi-Fi Location Database as opposed to other location techniques such as Cell ID, cell tower triangulation, and GPS. 10

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RESPONSE TO REQUEST FOR PRODUCTION NO. 185: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, , including without limitation in its use of the terms “comparative accuracy,” “Google Wi-Fi Location Database,” and “other location techniques,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 8 and 9, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 8 and 9. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 186: All Documents Relating To the structure, function, and operation of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database

11

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as used in conjunction with Google mobile services applications on a Wi-Fi enabled device such as an Android Enabled Mobile Phone or Tablet. RESPONSE TO REQUEST FOR PRODUCTION NO. 186: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” “Google mobile services applications,” Wi-Fi enabled device” and “Android Enabled Mobile Phone or Tablet,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 10, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 10. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, including

12

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but not limited to all relevant source code, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 187: All Documents Relating To the research and development of Google Location, including blueprints, schematics, drawings, diagrams, notebooks, lab books, memoranda, data sheets, computer logs, electronic files, Software, and other records of activity, including as they Relate To calculating a location using Wi-Fi signals, generating a database of Wi-Fi access points and associated location information, detecting and correcting errors in such database, utilizing Wi-Fi location information in conjunction with other location techniques such as Cell ID, cell tower triangulation, and GPS, identifying new Wi-Fi access points, or otherwise. RESPONSE TO REQUEST FOR PRODUCTION NO. 187: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Software,” “associated location information,” “Wi-Fi location information,” and “other location techniques,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 11, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 11. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). 13

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 188: All Documents Relating To the design, manufacture, and functionality of Google Location, including Software, specifications, schematics, flow charts, and other technical Documents including as they Relate To calculating a location using Wi-Fi signals, generating a database of Wi-Fi access points and associated location information, detecting and correcting errors in such database, utilizing Wi-Fi location information in conjunction with other location techniques such as Cell ID, cell tower triangulation, and GPS, identifying new Wi-Fi access points, or otherwise. RESPONSE TO REQUEST FOR PRODUCTION NO. 188: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Software,” “associated location information,” “Wi-Fi location information,” and “other location techniques,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 12, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 12. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

14

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 189: All presentations, training materials, user guides, manuals, memoranda, or other instructional Documents Relating To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 189: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 13, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 13. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

15

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 190: All Documents Relating To the identity, structure, function, operation, design, development, and creation of hardware, including servers, used to collect, process, and store Wi-Fi location data and provide Google Location beginning in 2007 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 190: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 14 and 15, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 14 and 15. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

16

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 191: Documents sufficient to identify the location of each Google Location server. RESPONSE TO REQUEST FOR PRODUCTION NO. 191: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 14 and 15, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 14 and 15. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). 17

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 192: All Documents Relating To any data, information, or records Concerning Wi-Fi access points used, organized, stored, recorded, collected, added, generated, modified, updated, or calculated as part of Google Location, including Google’s Wi-Fi location database and raw scan data and all source code Relating to the collection of Wi-Fi access point data, processing such data into the Google Wi-Fi location database, and the source code of the Wi-Fi location database itself. RESPONSE TO REQUEST FOR PRODUCTION NO. 192: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google’s Wi-Fi location database,” and “raw scan data,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 16, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 16. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

18

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 193: All Documents Relating To how data, information, or records in the Google Wi-Fi Location Database is used, organized, stored, recorded, collected, added, generated, modified, updated, or calculated, including Google’s Wi-Fi location database and raw scan data and all source code Relating to the collection of Wi-Fi access point data, processing such data into the Google Wi-Fi location database, and the source code of the Wi-Fi location database itself. RESPONSE TO REQUEST FOR PRODUCTION NO. 193: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, , including without limitation in its use of the terms “Google Wi-Fi Location Database” and “raw scan data,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 17, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 17. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The 19

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 194: All Documents Relating To the structure, function, and operation of the source code electing, initiating, or controlling any communications or transmissions between Wi-Fi access points and Wi-Fi-enabled devices or devices having a Wi-Fi radio as part of Google Location, including all such source code itself. RESPONSE TO REQUEST FOR PRODUCTION NO. 194: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “electing” and “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 18, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 18. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

20

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 195: All Documents Relating To the structure, function, and operation of computer hardware, Software, or algorithms used in Google Location, including hardware specifications and inventories, functional specifications, and all source code. RESPONSE TO REQUEST FOR PRODUCTION NO. 195: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 19, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 19. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

21

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 196: All Documents Relating To the structure, function, and operation of computer hardware, Software, or algorithms used in Google Location to determine the location of a Wi-Fi-enabled device or a device having a Wi-Fi radio, including hardware specifications and inventories, functional specifications, and all source code. RESPONSE TO REQUEST FOR PRODUCTION NO. 196: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Software,” “Google Location,” and “Wi-Fi-enabled device,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 20, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 20. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The

22

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 197: All articles, speeches, symposiums, conference papers, abstracts, and other publications, whether generated by Google or otherwise, Relating To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 197: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 21, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 21. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 198: All Documents Relating To Google’s participation in conferences or trade shows in which Google Location, or literature relating thereto, was displayed, promoted, sold, or otherwise discussed. RESPONSE TO REQUEST FOR PRODUCTION NO. 198: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 22, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 22. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 199: All Documents Relating To any agreements with Motorola, Samsung, LG, HTC, any other OEM, or any Person Concerning Google Location, including all documents reflecting negotiations concerning any such agreement.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 199: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 23, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 23. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 200: All Documents Relating To any Communications with Motorola, Samsung, LG, HTC, any other OEM, or corporate or governmental entity, Concerning Google Location, including marketing materials. 25

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RESPONSE TO REQUEST FOR PRODUCTION NO. 200: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 24, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 24. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 201: All Documents including specifications, user guides, manuals, instructional Documents, or Technical Documents provided by Google to Motorola, Samsung, LG, HTC, any other OEM, or any Person Relating To Google Location. 26

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RESPONSE TO REQUEST FOR PRODUCTION NO. 201: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 25, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 25. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 202: All marketing and sales Documents Relating To Google Location, including product literature, promotional brochures, catalogues, press releases, and advertisements. RESPONSE TO REQUEST FOR PRODUCTION NO. 202: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this

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action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 26, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 26. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 203: All Google press releases or draft press releases that discuss (1) Google Location, (2) location determination technology, (3) the Patents-in-Suit or the Related Patents, (4) Skyhook Technology, (5) Skyhook, or (6) this litigation. RESPONSE TO REQUEST FOR PRODUCTION NO. 203: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Patents-inSuit,” “Related Patents,” and “Skyhook Technology,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or 28

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that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 27, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 27. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 204: All Documents Relating To Your strategic plans, business plans, business strategies, licensing plans, licensing proposals, licensing forecasts, prospectuses, market surveys, marketing strategies, market analyses, and/or marketing forecasts of customer demand for Google Location beginning in 2007 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 204: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the

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extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 28, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 28. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 205: All Documents Relating To analyst reports, industry surveys, and published studies about the location determination industry, including article searches on specific attributes and competitive analyses of the location determination market that have been known to Google employees whose work involves the design, development, creation, marketing, maintenance, or provision of Google Location, beginning in 2007 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 205: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “location determination industry” and “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the 30

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discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 29, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 29. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 206: Documents sufficient to identify all product lines, features, names, and codes for Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 206: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including

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without limitation Request No. 30, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 30. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 207: All Documents Relating To internal and external financial statements, profitability studies and reports, gross-margin studies and reports, and turnover studies and reports for Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 207: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 32 and 110, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 32 and 110.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 208: Documents sufficient to identify your accounting methods for revenues, cost allocation, and profits for Google Location, including accounting procedures manuals and charts of accounts. RESPONSE TO REQUEST FOR PRODUCTION NO. 208: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 33, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 33. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 209: Documents sufficient to show the total research and development costs of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 209: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 34, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 34. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 210: All Documents Relating To sales and revenue information for Google Location from August 30, 2007, to the present, broken down by quarter and by U.S. versus worldwide sales and revenue, including all Documents sufficient to explain any acronyms or terminology employed by Google’s accounting system, and including sales volume and amount of revenue for products and

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services that Google Location comprises, groups, divisions, or other units, responsible for the same. RESPONSE TO REQUEST FOR PRODUCTION NO. 210: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 35, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 35. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 211: All Documents Relating To profit and margin information, including gross profits, operating profits, net profits, and profits before taxes, for Google Location from August 30, 2007,to the present, broken down by quarter and by U.S. versus worldwide sales and revenue, including profit and loss statements for products and services that Google Location comprises or that use location estimates provided by Google Location and business segments, groups, divisions, or other units, responsible for the same, and including all Documents sufficient to explain any acronyms or terminology employed by Google’s accounting system. RESPONSE TO REQUEST FOR PRODUCTION NO. 211: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 36, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 36.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 212: Documents sufficient to identify the total uses of Google Location on a monthly or quarterly basis. RESPONSE TO REQUEST FOR PRODUCTION NO. 212: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the phrase “total uses of Google Location” and the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 37, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 37. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request.

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REQUEST FOR PRODUCTION NO. 213: All Documents Relating To sales and revenue associated with Google Location (i.e., products and services that Google Location comprises or that use location estimates provided by Google Location and business segments, groups, divisions, or other units, responsible for the same), including reports, forecasts, and strategic plans. RESPONSE TO REQUEST FOR PRODUCTION NO. 213: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 38, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 38. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request.

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REQUEST FOR PRODUCTION NO. 214: All Documents Relating To advertising sales associated with Google Location, including sales reports, sales forecasts, and strategic plans beginning in 2007 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 214: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 39, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 39. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126).

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 215: All Documents Relating To forecasted, contemplated, planned or prospective gross and net profit or loss for Google Location (i.e., products and services that Google Location comprises or that use location estimates provided by Google Location and business segments, groups, divisions, or other units, responsible for the same), including profit margins and profit and loss statements. RESPONSE TO REQUEST FOR PRODUCTION NO. 215: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 40, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 40.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 216: All Documents Relating To forecasted, contemplated, planned or prospective planned or prospective gross and net profit or loss for the use of Google Location (i.e., products and services that Google Location comprises or that use location estimates provided by Google Location and business segments, groups, divisions, or other units, responsible for the same) in any region outside of the United States, including profit margins and profit and loss statements. RESPONSE TO REQUEST FOR PRODUCTION NO. 216: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 41, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 41. 41

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 217: All Documents Relating To market and customer demand, need, or market potential for Google Location (i.e., products and services that Google Location comprises or that use location estimates provided by Google Location and business segments, groups, divisions, or other units, responsible for the same) or location determination technology. RESPONSE TO REQUEST FOR PRODUCTION NO. 217: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 42, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 42. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 218: All Documents reviewed by, prepared by, or received by Google Relating To any test, evaluation, analysis, study, or investigation of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 218: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 45, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 45. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 219: All Documents Relating To customer or user comments, questions, or complaints Concerning Google Location.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 219: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 46, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 46. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 220: All Documents Relating To any actual, proposed, forecasted, contemplated, planned, or prospective business plan or strategy Concerning Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 220: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google

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objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 48, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 48. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 221: All Documents Relating To any actual, proposed, forecasted, contemplated, planned or prospective business plan or strategy Concerning the use of Google Location in any region outside of the United States. RESPONSE TO REQUEST FOR PRODUCTION NO. 221: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including 45

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without limitation Request No. 49, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 49. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 222: All Documents Relating To any actual, proposed, forecasted, contemplated, planned or prospective business plan or strategy Concerning the Patents-in-Suit, the Related Patents, or Skyhook Technology. RESPONSE TO REQUEST FOR PRODUCTION NO. 222: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit,” “Related Patents,” and “Skyhook Technology,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 50, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 50. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has 46

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 223: All Documents and Communications Relating To license agreements or royalty agreements entered into by Google as a licensee in technological fields including geolocation, location services, mobile services, and targeted advertising, beginning in 2003 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 223: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the phrase “technological fields including geolocation, location services, mobile services, and targeted advertising,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 51, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 51. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. 47

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REQUEST FOR PRODUCTION NO. 224: All Documents and Communications Relating To patent license agreements, settlement agreements, or other agreements containing a license to patent rights, to which Google is or was a party including patents in the fields of geolocation, location services, mobile services, and targeted advertising, beginning in 2003 to the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 224: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the phrase “technological fields including geolocation, location services, mobile services, and targeted advertising,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 52, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 52. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request.

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REQUEST FOR PRODUCTION NO. 225: All Documents and Communications Relating To license agreements, settlement agreements, or other agreements Relating To Google Location or Skyhook Technology and all products or services utilizing said technologies. RESPONSE TO REQUEST FOR PRODUCTION NO. 225: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Skyhook Technology,” and “all products or services utilizing said technologies,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the workproduct doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 53, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 53. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 226: All Documents and Communications Relating To end user license agreements, software license agreements, or any other licenses for use of or access to Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 226: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 54, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 54. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 227: All Documents Relating To Your corporate licensing policy, practices, or procedures, with respect to licensing of intellectual property or software Relating to Google Location or other location-related technology, and with respect to licensing patents.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 227: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location” and “other location-related technology,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 55, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 55. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 228: All Documents Relating To indemnity agreements or any agreements of any kind Concerning (a) the Patents-in-Suit or the Related Patents or (b) this litigation.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 228: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 59, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 59. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 229: All Documents Relating To any meeting with stock, financial, or similar analysts at which Google Location was discussed. RESPONSE TO REQUEST FOR PRODUCTION NO. 229: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the

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grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 60, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 60. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 230: All Documents Relating To any marketing plan, competitive assessment, market share study, marketing budget, advertising budget, or promotion strategy plans Concerning Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 230: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google

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objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 61, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 61. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 231: All Documents Relating To advertisements, including internet web pages, made by or on behalf of Motorola, Samsung, LG, HTC, any other OEM, or any other Person Concerning Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 231: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to 54

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this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 62, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 62. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 232: All Documents Relating To any Communications with Motorola, Samsung, LG, HTC, any other OEM, or any Person Concerning: (1) Google Location, (2) location determination technology, (3) the Patents-in-Suit or the Related Patents, (4) Skyhook Technology, (5) Skyhook, or (6) this litigation. RESPONSE TO REQUEST FOR PRODUCTION NO. 232: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “location determination technology,” “Patents-in-Suit,” “Related Patents,” and “Skyhook Technology,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 63, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 63.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 233: Documents sufficient to identify the organizational structure, location, and personnel of each of Your units, departments, divisions, or other entities involved in the research, development, production, manufacture, marketing, or sales of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 233: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 65, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 65. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. 56

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REQUEST FOR PRODUCTION NO. 234: Documents sufficient to identify the name, location, title and role of all employees involved in the research, development, production, manufacture, marketing, or sales of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 234: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 66, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 66. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 235: All board of directors minutes, memoranda, reports, meeting agendas and other Documents, including Documents of any board committee, subcommittee or similar group, Relating To (1) Google Location, (2) location determination technology, (3) the Patents-in-Suit or the Related Patents, (4) Skyhook Technology, (5) Skyhook, or (6) this litigation.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 235: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “location determination technology,” “Patents-in-Suit,” “Related Patents,” and “Skyhook Technology,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 67, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 67. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 236: All reports, meeting agendas, meeting minutes and other Documents of management, sales, and marketing personnel Relating To (1) Google Location, (2) location determination technology, (3) the Patents-in-Suit or the Related Patents, (4) Skyhook Technology, (5) Skyhook, or (6) this litigation.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 236: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “location determination technology,” “Patents-in-Suit,” “Related Patents,” and “Skyhook Technology,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 68, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 68. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 237: All internal memoranda, newsletters, bulletins, and other Documents Relating To (1) Google Location, (2) location determination technology, (3) the Patents-in-Suit or the Related Patents, (4) Skyhook Technology, (5) Skyhook, or (6) this litigation. RESPONSE TO REQUEST FOR PRODUCTION NO. 237: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “location

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determination technology,” “Patents-in-Suit,” “Related Patents,” and “Skyhook Technology,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 69, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 69. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 238: All Documents Relating To when and how Google first became aware of the existence of the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 238: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the

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attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 70, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 70. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that documents responsive to this request, as it relates to the patents asserted in Skyhook II – the Complaint filed in Skyhook II and its exhibits – are in the possession of Skyhook. REQUEST FOR PRODUCTION NO. 239: All Documents Relating To actions that Google took upon becoming aware of the existence of the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 239: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests,

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including without limitation Request No. 71, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 71. REQUEST FOR PRODUCTION NO. 240: All Documents Relating To any Communications with Skyhook Relating To Skyhook Technology, the Patents-in-Suit, or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 240: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “ “Patents-in-Suit,” “Related Patents,” and “Skyhook Technology,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 73, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 73. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I.

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REQUEST FOR PRODUCTION NO. 241: All Documents reviewed by, prepared by, or received by Google Relating To any test, evaluation, analysis, study, or investigation of the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 241: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 75, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 75. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 242: All Documents Relating To searches or investigations Relating To the scope, validity, infringement, or enforceability of each of the Patents-in-Suit or the Related Patents.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 242: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 76, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 76. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 243: All Documents Relating To any analysis, opinion, or inquiry regarding potential infringement of the inventions claimed in each of the Patents-in-Suit or the Related Patents, including but not limited to any Documents Concerning pre-litigation investigations performed by or on behalf of Defendant, Defendant’s partners, Defendant’s licensors, Defendant’s customers, Defendant’s resellers, and/or Defendant’s affiliates, Relating To the potential infringement by any products, systems, or processes made, used, offer for sale, and/or sold by Defendant, Defendant’s partners, Defendant’s licensors, Defendant’s customers, Defendant’s resellers, and/or Defendant’s affiliates.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 243: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 77, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 77. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 244: All Documents Relating To any risk or damages analysis of potential infringement of the Patents-in-Suit or the Related Patents.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 78: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 78, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 78. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 245: All Documents Relating To any written or oral opinion of counsel Concerning the Patents-inSuit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 245: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related

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Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 79, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 79. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 246: All Documents Relating To the validity or invalidity of any of the claims of the Patents-In-Suit or the Related Patents, including any prior art, claim charts, invalidity charts, validity search, prior art search or patentability search conducted in connection with the Patents-In-Suit or the Related Patents, including search reports or requests or instructions for prior art searches. RESPONSE TO REQUEST FOR PRODUCTION NO. 246: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible

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evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 80, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 80. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 247: Assuming that Google were held to infringe the Patents-in-Suit, all Documents upon which Google relies, or intends to rely, to support its position that such infringement is not deliberate or willful. RESPONSE TO REQUEST FOR PRODUCTION NO. 247: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Patents-in-Suit,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in 68

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the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 82, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 82. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 248: All Documents Relating To Your analysis of the liability or risk factors associated with the development of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 248: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the phrase “liability or risk factors” and the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or

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duplicative of other Requests, including without limitation Request No. 83, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 83. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 249: All Documents Relating To any comparisons between the Patents-in-Suit or the Related Patents and any Google products, systems, or processes. RESPONSE TO REQUEST FOR PRODUCTION NO. 249: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 84, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 84. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will

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produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 250: All Documents Relating To any comparisons between Skyhook Technology and Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 250: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location” and “Skyhook Technology,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 85, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 85. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request.

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REQUEST FOR PRODUCTION NO. 251: All Documents Relating To the use of GPS, Assisted GPS, Cell ID, or cell tower triangulation in Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 251: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 86, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 86. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request.

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REQUEST FOR PRODUCTION NO. 252: All Documents Relating To any comparisons between Google Location and GPS, Assisted GPS, Cell ID, or cell tower triangulation. RESPONSE TO REQUEST FOR PRODUCTION NO. 252: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 87, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 87. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 253: All Documents that have any bearing on the interpretation or construction of the claims of the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 253: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related

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Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 88, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 88. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 254: All Documents Relating To Your policy or practice, whether formal or informal, Concerning the analysis of patents owned by or assigned to entities other than Google, including patents in the fields of location services technology, location-based marketing, and geolocation. RESPONSE TO REQUEST FOR PRODUCTION NO. 254: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “location services technology,” “location-based marketing,” and “geolocation,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information 74

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concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 90, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 90. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 255: All Documents Relating To Your policy or practice, whether formal or informal, Concerning the comparison of any Google products, systems, or processes with the claims of patents owned by or assigned to entities other than Google including patents in the field of location technology or geolocation. RESPONSE TO REQUEST FOR PRODUCTION NO. 255: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “location technology” and “geolocation,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused

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in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 5, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 5. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 256: All Documents Relating To any analysis or effort by Google to design products around the Patents-in-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 256: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the

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extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 94, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 94. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 257: All Documents Relating To design alternative studies or design change orders for Google Location, including engineer lab notebooks, notes, memoranda, electronic mail messages, schematics, block diagrams, blue prints, drawings, and Software. RESPONSE TO REQUEST FOR PRODUCTION NO. 257: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Software” and “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or 77

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duplicative of other Requests, including without limitation Request Nos. 94, 95, and 256, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 94, 95, and 256. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 258: All Documents Relating To technical or financial studies Concerning the value or application of the inventions claimed in the Patents-In-Suit or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 258: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request

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No. 96, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 96. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I. REQUEST FOR PRODUCTION NO. 259: All Documents Relating To technical or financial studies Concerning the value or application of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 259: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “application” and “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests,

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including without limitation Request No. 98, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 98. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 260: All Documents Relating To any product, system, or process that competes with Google Location including any documents Relating to Your testing, analysis, or planning with respect to such competing products. RESPONSE TO REQUEST FOR PRODUCTION NO. 260: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 99, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 99. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The 80

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Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 261: All market studies, consumer analyses, and competitive analyses Relating To any product, system, or process that competes with Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 261: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 100 and 260, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 100 and 260. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 262: All versions of Software that has been or is being used in Google Location including all source code. RESPONSE TO REQUEST FOR PRODUCTION NO. 262: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Software” and “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 101, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 101. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 263: All Documents Relating To the structure, function, and operation of Software that has been or is being used in Google Location, including functional specifications and source code. RESPONSE TO REQUEST FOR PRODUCTION NO. 263: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Software” and “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 101, 102 and 262, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 101, 102 and 262. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 264: All Documents, including Software, functional specifications, and source code, Relating To any updates of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 264: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Software” and “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 101, 103 and 262, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 101, 103 and 262. Google further objects to this Request on the grounds stated in Google Inc.’s Opposition To Skyhook’s Supplemental Brief Regarding Skyhook’s Motion To Compel The Production Of Documents Responsive To Skyhook’s Requests For Production And Skyhook’s Proposed Reply In Support Thereof (D.I. 126). Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has

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produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 265: All Documents furnished to, or discussed with, any fact witness contacted, interviewed, or consulted by Google or its agents or attorneys in connection with this litigation, the Patents-inSuit, or the Related Patents. RESPONSE TO REQUEST FOR PRODUCTION NO. 265: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Patents-in-Suit” and “Related Patents,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 106, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 106. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I.

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REQUEST FOR PRODUCTION NO. 266: All financial statements from August 30, 2007, to present Relating To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 266: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 110 and 112, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 110 and 112. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 267: All financial statements from August 30, 2007, to present of any and all of Your business segments, groups, divisions, sectors and/or subsidiaries Relating To Google Location.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 267: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 112, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 112. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 268: All profit and loss statements from August 30, 2007, to present Relating To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 268: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the

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grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 114, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 114. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 269: Documents sufficient to identify Your profit or loss Relating To Google Location for each quarter and year from August 30, 2007, to present. RESPONSE TO REQUEST FOR PRODUCTION NO. 269: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google

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further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 116, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 116. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 270: Documents sufficient to identify Your revenue, for each quarter and year from August 30, 2007, to present, Relating To Google Location for each quarter and year from August 30, 2007, to present. RESPONSE TO REQUEST FOR PRODUCTION NO. 270: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in 89

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Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 118, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 118. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 271: Documents sufficient to identify all expense items, for each quarter and year from August 30, 2007, to present, including but not limited to, cost of goods sold, sales and marketing, research and development, and general and administrative, Relating To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 271: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Location,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product 90

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doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 120, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 120. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 272: Documents sufficient to show the structure, function, operation, design, development, testing, valuation and forecasts Relating To Google’s Location-Based Advertising. RESPONSE TO REQUEST FOR PRODUCTION NO. 272: Google objects to this Request as vague, ambiguous, and unintelligible, including without limitation in its use of the terms or phrases “structure . . . Relating to Google’s Location-Based Advertising,” “function . . . . . . Relating to Google’s Location-Based Advertising,” “operation . . . Relating to Google’s Location-Based Advertising,” “design . . . Relating to Google’s Location-Based Advertising,” “development . . . Relating to Google’s Location-Based Advertising,” “testing . . . Relating to Google’s Location-Based Advertising,” and “LocationBased Advertising,” as overly broad and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the

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work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 122-132, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 122-132. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 273: Documents sufficient to show the structure, function, operation, design, development, testing, valuation and forecasts Relating To Mobile Advertising as it Relates To Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 273: Google objects to this Request as vague, ambiguous, and unintelligible, including without limitation in its use of the terms or phrases “structure . . . Relating to Mobile Advertising as it Relates To Google Location,” “function . . . . . . Relating to Mobile Advertising as it Relates To Google Location,” “operation . . . Relating to Mobile Advertising as it Relates To Google Location,” “design . . . Relating to Mobile Advertising as it Relates To Google Location,” “development . . . Relating to Mobile Advertising as it Relates To Google Location,” “testing . . . Relating to Mobile Advertising as it Relates To Google Location,” and “Google Location,” as overly broad and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the

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extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 133-143, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 133-143. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 274: Documents sufficient to identify the total number of Wi-Fi enabled devices in the United States, by quarter and by year for each year from August 30, 2007, to the present, that have or had Google Location installed, downloaded or uploaded on them. RESPONSE TO REQUEST FOR PRODUCTION NO. 274: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location” and “Wi-Fi enabled devices,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent 93

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that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 144-145, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 144-145. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 275: Documents sufficient to identify the total number of Wi-Fi enabled devices in the United States, by quarter and by year for each year from August 30, 2007, to the present, that have or had any application making use of Google Location, installed, downloaded, or uploaded on them. RESPONSE TO REQUEST FOR PRODUCTION NO. 275: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location” and “Wi-Fi enabled devices,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google 94

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objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 146-147, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 146-147. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 276: All Documents Relating To any presentation made to shareholders, potential shareholders, investors, potential investors, lenders, potential lenders, analysts, and/or members of the economic media Relating To Google Location, Location Determination Technologies, LocationBased Advertising, and/or Mobile Advertising. RESPONSE TO REQUEST FOR PRODUCTION NO. 276: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” Location Determination Technologies,” “Location-Based Advertising,” and “Mobile Advertising,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without

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limitation Request No. 156, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 156. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 277: All Documents Relating To any study, survey, or analysis Relating To Location-Based Advertising, Mobile Advertising, and/or any or all Google Location products. RESPONSE TO REQUEST FOR PRODUCTION NO. 277: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Location-Based Advertising” “Mobile Advertising,” and “Google Location products,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 158, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 158.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request. REQUEST FOR PRODUCTION NO. 278: All versions of Software that has been or is being used in Google’s Wi-Fi Location Database, including source code. RESPONSE TO REQUEST FOR PRODUCTION NO. 278: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Software” and “Wi-Fi Location Database,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 174-175, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 174-175. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google states that it has produced such non-privileged documents as exist in its possession, custody, or control, as have been located after a reasonable and good faith search that are responsive to this Request.

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REQUEST FOR PRODUCTION NO. 279: All Documents Relating to the use of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to estimate an expected error of a position estimate or otherwise estimate a distance between a calculated position and an actual position. RESPONSE TO REQUEST FOR PRODUCTION NO. 279: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” “Android Enabled Mobile Phone or Tablet,” and “expected error,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request.

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REQUEST FOR PRODUCTION NO. 280: All Documents Relating to the use of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to estimate an expected error of a position estimate based in whole or in part on signal strength, estimated geographic location, or signal coverage area. RESPONSE TO REQUEST FOR PRODUCTION NO. 280: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” “Android Enabled Mobile Phone or Tablet,” and “expected error,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request.

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REQUEST FOR PRODUCTION NO. 281: All Documents Relating to the use of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to determine that a previous location of a Wi-Fi access point has changed or is incorrect. RESPONSE TO REQUEST FOR PRODUCTION NO. 281: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” and “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 5, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 5. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted

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in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 282: All Documents Relating to the use of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to determine that a location associated with a Wi-Fi access point is not the present location of the Wi-Fi access point. RESPONSE TO REQUEST FOR PRODUCTION NO. 282: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” and “Android Enabled Mobile Phone or Tablet,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 281, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 281. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be

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responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 283: All Documents Relating to the use of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to calculate the position of a device based on information gathered from Wi-Fi access points by the device and information about the Wi-Fi access points. RESPONSE TO REQUEST FOR PRODUCTION NO. 283: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” and “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 281-282, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 281-282. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith

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search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 284: All Documents Relating to the use of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to estimate the position of a device using information from Wi-Fi access points and to use such estimate as an initial position for a satellite positioning system. RESPONSE TO REQUEST FOR PRODUCTION NO. 284: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” and “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 281-283, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 281-283. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will

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produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 285: All Documents Relating to the use of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to calculate an uncertainty estimate in a position estimated by using information from Wi-Fi access points and to provide such uncertainty estimate along with an initial position to a satellite positioning system. RESPONSE TO REQUEST FOR PRODUCTION NO. 285: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” “Android Enabled Mobile Phone or Tablet,” and “uncertainty estimate,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-284, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-284. 104

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 286: All Documents Relating to the use of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to estimate the geographic location of a device by using, in whole or in part, user-input information relating to Wi-Fi access points. RESPONSE TO REQUEST FOR PRODUCTION NO. 286: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” “Android Enabled Mobile Phone or Tablet,” and “user-input information relating to Wi-Fi access points,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the workproduct doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos.

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280-285, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-285. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 287: All Documents Relating to https://services.google.com/fb/forms/wifibugs/, including without limitation the submissions received through this service, dates and number of submissions received through this service, and the date and reasons why Google discountinued [sic] the service. RESPONSE TO REQUEST FOR PRODUCTION NO. 287: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google.

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Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 288: All Documents Relating to the use of Android Enabled Mobile Phones or Tablets to gather information about Wi-Fi access points, including without limitation identifying the location of access points, or determining that the access points have moved. RESPONSE TO REQUEST FOR PRODUCTION NO. 288: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted

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in Skyhook I—excluding source code, as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 289: All Documents Relating To caching of information on Android Enabled Mobile Phones or Tablets about detected Wi-Fi access points, including all documents concerning the use of such cached data to estimate the position or movement of Android Enabled Mobile Phones or Tablets, or to provide location-based services. RESPONSE TO REQUEST FOR PRODUCTION NO. 289: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 280-286, and seeks materials previously produced by Google. Google incorporates herein its Response to Request No. 280-286. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted

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in Skyhook I—excluding source code, as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 290: All Documents Relating To the cache.wifi cache on Android Enabled Mobile Phones or Tablets, including all documents concerning the use of the contents of cache.wifi (including time data) to estimate the position or movement of Android Enabled Mobile Phones or Tablets, or to provide location-based services. RESPONSE TO REQUEST FOR PRODUCTION NO. 290: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted

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in Skyhook I—excluding source code, as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 291: All Documents Relating To the use of cached information on Android Enabled Mobile Phones or Tablets about detected Wi-Fi access points by either the Android Enabled Mobile Phones or Tablet on which the data is cached, or by the Google Location Server. RESPONSE TO REQUEST FOR PRODUCTION NO. 291: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location Server,” and “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request No. 280-286, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted 110

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in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 292: All Documents Relating to the use of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to identify new Wi-Fi access points. RESPONSE TO REQUEST FOR PRODUCTION NO. 292: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” and “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-285, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-285. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted 111

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in Skyhook I—excluding source code, as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 293: All Documents Relating to the use of Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet to add information about new Wi-Fi access points to the Google Wi-Fi Location Database or otherwise utilize such information for Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 293: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” “Android Enabled Mobile Phone or Tablet,” and “otherwise utilize such information for Google Location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the workproduct doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286 and 292, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286 and 292. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith

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search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 294: All Documents Relating to the use in Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet, of GPS or other satellite positioning data, whether in conjunction with Wi-Fi location data, cell tower location data, or otherwise. RESPONSE TO REQUEST FOR PRODUCTION NO. 294: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” and “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286 and 292-293, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286 and 292-293.

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Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 295: All Documents Relating to the use in Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet, of cell tower location data, whether in conjunction with GPS or other satellite positioning data, Wi-Fi location data, or otherwise. RESPONSE TO REQUEST FOR PRODUCTION NO. 295: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” and “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286 and 292-294, and seeks materials previously

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produced by Google. Google incorporates herein its Response to Request No. 280-286 and 292294. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 296: All Documents Relating to the use in Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet, of any form of location data or method of estimating a location other than Wi-Fi location data, whether in conjunction with Wi-Fi location data or otherwise. RESPONSE TO REQUEST FOR PRODUCTION NO. 296: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” “Android Enabled Mobile Phone or Tablet,” and “any other method of estimating a location other than Wi-Fi location data,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the

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public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286 and 292-295, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286 and 292-295. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 297: All Documents Relating to the use in Google Location, Google Location Service, Google’s Network Location Provider, or the Google Wi-Fi Location Database, or any Android Enabled Mobile Phone or Tablet, of GPS or other satellite positioning data in conjunction with updating or correcting the Google Wi-Fi Location Database or any aspect of Google Location. RESPONSE TO REQUEST FOR PRODUCTION NO. 297: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google Location,” “Google Location Service,” “Google Wi-Fi Location Database,” and “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the

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extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 280-286 and 292-296, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 280-286 and 292-296. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request as it relates to patents in Skyhook’s Amended Complaint not asserted in Skyhook I—excluding source code as Google has produced all source code responsive to this Request. REQUEST FOR PRODUCTION NO. 298: All Documents Relating to MacWorld 2008. RESPONSE TO REQUEST FOR PRODUCTION NO. 298: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through

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less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 299: All Documents Relating to Google’s communications with Apple concerning location-based services. RESPONSE TO REQUEST FOR PRODUCTION NO. 299: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “location-based services,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 300: All Documents You produced in any civil or criminal investigations, administrative proceedings, or litigations, Relating To Google’s Street View project.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 300: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 163-165, and seeks materials previously produced by Google. Google further objects to this Request on the grounds stated in its Supplemental Responses to Request Nos. 163-165. REQUEST FOR PRODUCTION NO. 301: All Documents Relating To location data that You produced in any civil or criminal investigations, administrative proceedings, or litigations, Relating To Google’s Street View project. RESPONSE TO REQUEST FOR PRODUCTION NO. 301: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through

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less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 163-165 and 301, and seeks materials previously produced by Google. Google further objects to this Request on the grounds stated in its Supplemental Responses to Request Nos. 163-165. REQUEST FOR PRODUCTION NO. 302: All Documents Relating To Wi-Fi data collection that You produced in any civil or criminal investigations, administrative proceedings, or litigations, Relating To Google’s Street View project. RESPONSE TO REQUEST FOR PRODUCTION NO. 302: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 163-165 and 301-302, and seeks materials previously produced by Google. Google further objects to this Request on the grounds stated in its Supplemental Responses to Request Nos. 163-165. REQUEST FOR PRODUCTION NO. 303: All Documents or Things produced or made available for inspection in TracBeam, L.L.C. v. Google, Inc., Case No. 6:13-cv-00093, including without limitation depositions and discovery responses.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 303: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 304: All Documents Relating to Google’s use of location-based data in providing Location-Based Advertising or Mobile Advertising, including without limitation the use of AdWords service. RESPONSE TO REQUEST FOR PRODUCTION NO. 304: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “location-based data,” “Location-Based Advertising,” “Mobile Advertising,” and “AdWords service,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the workproduct doctrine. Google objects to this Request to the extent that it seeks information that is

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within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, including without limitation Request Nos. 122-143 and 272-273, and seeks materials previously produced by Google. Google incorporates herein its Response to Request Nos. 122-143 and 272-273. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 305: All Documents Relating to any tests, evaluations, comparisons, or other analysis of any changes to Google’s Wi-Fi-based location services, including for example any changes in completeness of the Google Wi-Fi Location Database, accuracy, time to fix, uncertainty, or error, between 2007 and the present. RESPONSE TO REQUEST FOR PRODUCTION NO. 305: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google’s Wi-Fi-based location services,” “completeness,” “Google Wi-Fi Location Database,” “accuracy,” “time to fix,” “uncertainty,” and “error,” and the phrase “any changes in completeness of the Google Wi-Fi Location Database, accuracy, time to fix, uncertainty, or error,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the

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extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 306: All Documents Relating to the presence, usage, maintenance, or turnover of any data in the Google Wi-Fi Location Database from 2010 until the present that was collected during CityBlock or StreetView driving. RESPONSE TO REQUEST FOR PRODUCTION NO. 306: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Google Wi-Fi Location Database,” and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 307: Documents sufficient to show the total number of Android Enabled Mobile Phones or Tablets, by month, for each year from 2007 to the present, in the United States that are installed with any of the Google Location products.

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RESPONSE TO REQUEST FOR PRODUCTION NO. 307: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Android Enabled Mobile Phones or Tablets” and “Google Location products,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks any financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 308: Documents sufficient to show the total number of times, by month, for each year from 2007 to the present, of Android Enabled Mobile Phones or Tablets in the United States that have accessed Google’s Wi-Fi Location Database. RESPONSE TO REQUEST FOR PRODUCTION NO. 308: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google’s Wi-Fi Location Database” and “Android Enabled Mobile Phones or Tablets,” on the grounds that it seeks

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information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the workproduct doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 309: Documents sufficient to show the total number of times, by month, for each year from 2007 to the present, Wi-Fi enabled devices anywhere in the world have accessed Google’s Wi-Fi Location Database in the United States. RESPONSE TO REQUEST FOR PRODUCTION NO. 309: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Google’s Wi-Fi Location Database” and “Wi-Fi enabled devices,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily 125

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obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 310: Documents Relating To any valuation or attempted valuation of Wi-Fi based location data to Google, including without limitation the valuation shown in GOOGSKYFED_0181945 and any similar analyses. RESPONSE TO REQUEST FOR PRODUCTION NO. 310: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Wi-Fi based location data,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Subject to and without waiving the foregoing and all General Objections set forth above and in Exhibit A, and to the extent Google understands this request, Google has produced or will produce such representative, non-privileged documents as, after a reasonable and good faith search, Google determines exist in its possession, custody, or control, if any, that may be responsive to this Request. 126

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REQUEST FOR PRODUCTION NO. 311: Documents sufficient to show Google’s market share of the U.S. Mobile Advertising market from 2007 to the present, and anticipated market trends or forecasts through 2030. RESPONSE TO REQUEST FOR PRODUCTION NO. 311: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “Mobile Advertising” and “Mobile Advertising market,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 312: All Documents Relating To Google’s patents or patent applications relating to geolocation technology, geolocation devices, or geolocation products. RESPONSE TO REQUEST FOR PRODUCTION NO. 312: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “geolocation technology,” “geolocation devices,” and “geolocation products,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to

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lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 313: All Documents Relating To any estimates of the economic value of each of the following: Google-owned, Google-licensed, Google cross-licensed, non-Google, Skyhook, and nonSkyhook patented technology in Android Enabled Mobile Phones or Tablets related to location or Wi-Fi location. RESPONSE TO REQUEST FOR PRODUCTION NO. 313: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the phrase “Google-owned, Googlelicensed, Google cross-licensed, non-Google, Skyhook, and non-Skyhook patented technology,” and the terms “Android Enabled Mobile Phone or Tablet,” “related to location,” and “related to . . . Wi-Fi location,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or

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control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 314: All Documents Relating To any estimates of the economic value of the respective contributions of GPS, cell tower triangulation, and Wi-Fi to the overall economic value of location services provided in Android Enabled Mobile Phones or Tablets. RESPONSE TO REQUEST FOR PRODUCTION NO. 314: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the terms “overall economic value of location services,” “location services,” and “Android Enabled Mobile Phone or Tablet,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request.

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REQUEST FOR PRODUCTION NO. 315: All Documents Relating To costs to Google, on an annual and cumulative basis since 2004, to establish and maintain Wi-Fi-based geolocation services. RESPONSE TO REQUEST FOR PRODUCTION NO. 315: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, including without limitation in its use of the term “Wi-Fi-based geolocation services,” on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence, and to the extent that it seeks information concerning products not accused in this action. Google objects to this Request to the extent that it seeks documents protected by the attorney-client privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google. Google is willing to meet and confer with Skyhook concerning a reasonable scope for this Request. REQUEST FOR PRODUCTION NO. 316: All Documents authored, sent, or received by Sergey Brin, or in the network folders, email accounts, hard drives, or any other source of electronically stored information of Sergey Brin, Relating To Skyhook or Google’s strategic decisions and valuation Relating To Google Location, or including any of the following terms: • • • •
1

“Location-based services” or “LBS” “Location” or “Wi-Fi” or “WiFi” in the same document as “advert*” or “revenue” “Apple” or “*apple.com” in the same document as “Wi-Fi” or “Wi-Fi” or “data” “Wi-Fi location database” Any search term identified in the document entitled “Skyhook v. Google – ESI Information.pdf” that was sent via email to Skyhook’s counsel by Tom Lundin on March 27, 2013.

RESPONSE TO REQUEST FOR PRODUCTION NO. 316: Google objects to this Request as vague, ambiguous, overly broad, and unduly burdensome, and on the grounds that it seeks information that is irrelevant to the claims and defenses asserted in this action and is not reasonably calculated to lead to the discovery of admissible evidence. Google further objects to this Request as overbroad and unduly burdensome to the extent it seeks any financial information predating December 21, 2010, the earliest issue date of the patents in Skyhook’s Amended Complaint not asserted in Skyhook I. Google objects to this Request to the extent that it seeks documents protected by the attorneyclient privilege and/or the work-product doctrine. Google objects to this Request to the extent that it seeks information that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. Google objects to this Request to the extent that it is cumulative or duplicative of other Requests, and seeks materials previously produced by Google.

EXHIBIT A GENERAL OBJECTIONS 1. Google incorporates by reference each and every General Objection, Objection

To Definitions, and Objection To Instructions stated herein into each and every objection to an individually numbered request in the Third Requests. Google’s failure to include a General Objection, Objection To Definitions, or Objection To Instructions in a response to an individually numbered request shall not be interpreted as a waiver of that General Objection, Objection To Definitions, or Objection To Instructions. 2. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties. 3. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents or information that are not relevant to the claims or defenses in this action, or not reasonably calculated to lead to the discovery of admissible evidence. 4. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it is vague, indefinite, uncertain, ambiguous, or subject to more than one reasonable interpretation. 5. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it is overly broad, unduly burdensome, or oppressive.

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6.

Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents or information not in Google’s actual knowledge, possession, custody, or control; that is within Skyhook’s knowledge, possession, custody or control; that is in the public domain; or that is easily obtainable through less burdensome means. 7. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents or information without temporal limit or qualification, or is not limited to the relevant time period under 35 U.S.C. § 286. 8. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents or information protected by the attorney-client privilege, the attorney work product doctrine, or any other applicable law, privilege, doctrine, or other immunity from discovery. Google will not disclose any information so protected, and the inadvertent disclosure or identification of any such information is not intended as, and will not constitute, a waiver of such privilege, doctrine, or immunity. 9. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents, information, or discovery that calls for a legal conclusion. 10. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents, information, or discovery that is properly the subject of expert testimony.

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11.

Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it seeks documents, information, or discovery concerning products that are not accused in this action. 12. Google objects to the Third Requests, the Definitions, and the Instructions set

forth therein, and each request therein, to the extent that it is cumulative or duplicative; seeks documents or information already provided to Skyhook in response to other discovery in this action; or seeks documents or information obtainable from another source that is more convenient, less burdensome, or less expensive. 13. Discovery in this action is not yet complete. Google will conduct a diligent

search and reasonable inquiry in a good faith effort to discover documents responsive to the Third Requests and will produce relevant, responsive, non-privileged documents, subject to its general and specific objections, of which it becomes aware. Google reserves the right to amend and/or supplement its objections and responses to the Third Requests if and when any additional facts, information, or documents are discovered. Additionally, because Google bases its objections and responses on facts, information and documents that Google has identified to date, the foregoing objections and responses shall not preclude Google from later relying on facts, information, or documents discovered or generated pursuant to subsequent investigation or discovery. Google’s partial objection or response to any portion of the Third Requests shall not be construed as a waiver of any of its objections or responses, or its right to object or respond, to any other portion of the Third Requests. Google reserves the right to object to the relevance and/or admissibility of any information or documents provided in response to the Third Requests.

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14.

Google’s response to the Third Requests, and each individually numbered request

incorporated therein, is hereby made without in any way waiving or intending to waive, but rather, to the contrary, by preserving and intending to preserve: (a) All questions as to the competence, relevance, materiality, and admissibility as evidence for any purpose of the information or documents, or the subject matter thereof, in any aspect of this investigation or any other action or judicial or administrative proceeding or investigation; The right to object on any ground to the use of any such information or documents, or the subject matter thereof, in any aspect of this investigation or any other action or judicial or administrative proceeding or investigation; The right to object at any time for any further response to this or any other request for information or production of documents; and The right at any time to supplement this response.

(b)

(c) (d) 15.

By agreeing to produce documents in response to a particular request, Google

does not represent or acknowledge that such responsive documents exist. OBJECTIONS TO DEFINITIONS 1. Google objects to the Definitions set forth in the Third Requests to the extent that

any Definition purports to enlarge or alter in any way the plain meaning and scope of any specific request on the grounds that such enlargement or alteration renders the request vague, indefinite, uncertain, ambiguous, or subject to more than one reasonable interpretation. 2. Google objects to the Third Requests to the extent that any Definition, or any

request by its incorporation therein, to the extent that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties.

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3.

Google objects to the definition of “’954 Patent” because Skyhook has stated that

it is not asserting the ’954 Patent in this action. 4. Google objects to the definition of “’245 Patent” because the Court held the ’245

Patent invalid. See D.I. 96. 5. Google objects to the definition of “’988 Patent” because the Court held the ’988

Patent invalid. See D.I. 96. 6. Google objects to the definition of “Communication” to the extent that it is

inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties. 7. Google objects to the definition of “Concerning” or “Relating to” to the extent

that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; and as vague, indefinite, uncertain, ambiguous, or subject to more than one reasonable interpretation, and unintelligible, including without limitation because the definition includes the defined term “relating to.” 8. Google objects to the definition of “Document” to the extent that it is inconsistent

with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties. 9. Google objects to the definition of “Google,” “Defendant,” “You,” and “Your” as

overly broad, unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of

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admissible evidence, to the extent that it purports to include “all related entities, parents, subsidiaries or divisions, and any predecessor or successor entities and any of its officers, directors, agents, attorneys, consultants, accountants, employees, representatives, contractors, and any other persons acting, or purporting to act for or on its behalf.” Google interprets any reference to “Google,” “Defendant,” “You,” or “Your” in the Third Requests as referring to Google Inc. and will provide only responsive, non-privileged information that is in the possession, custody, or control of Google. 10. Google objects to the definition of “Google Location” as overly broad and unduly

burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, to the extent that it purports to include any “products, systems, or processes” not properly accused in this action or not within the scope of discovery in this action. Google interprets any reference to “Google Location” in the Third Requests as referring solely to the accused aspects of the accused product. 11. Google objects to the definition of “Google Wi-Fi Location Database” as vague,

ambiguous, and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence. Google hereby incorporates its objections to the definition of “Software.” 12. Google objects to the definition of “Mobile Advertising” as overly broad, unduly

burdensome, and irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence.

A-6

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13.

Google objects to the definition of “Location Determination Technologies” as

vague, ambiguous, and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence. 14. Google objects to the definition of “Location-Based Advertising” as vague,

ambiguous, and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, including without limitation to the extent that it purports to incorporate the definition of “Location Determination Technologies.” Google hereby incorporates its objections to the definition of “Location Determination Technologies.” 15. Google objects to the definition of “Android,” “Android Operating System,”

“Android OS,” “Google Maps,” “Google Latitude,” “Mozilla Firefox,” “Google Toolbar,” and “My Location” to the extent that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; as vague, ambiguous, and subject to more than one reasonable interpretation; as overly broad and unduly burdensome; and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence. 16. Google objects to the definition of “Patents-in-Suit” to the extent that it is

inconsistent with or seeks to impose on Google obligations greater than or different from those

A-7

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imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; as overly broad and unduly burdensome; and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, including without limitation to the extent that it purports to include the ‘945 Patent, which is not asserted; or the ‘245 Patent or ‘988 Patent, which the Court held invalid. See D.I. 96. 17. Google objects to the definition of “Related Patents” to the extent that it is

inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; as vague, ambiguous, and subject to more than one reasonable interpretation; as overly broad and unduly burdensome; and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, including without limitation to the extent that the term is used in any request in connection with the term “Patentsin-Suit.” 18. Google objects to the definition of “Skyhook” as overly broad, unduly

burdensome, and irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, to the extent that it purports to include “all related entities, parents, subsidiaries or divisions, and any predecessor or successor entities and any of its officers, directors, agents, attorneys, consultants, accountants, employees, representatives, and any other persons acting, or purporting to act for or

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on its behalf.” Google interprets any reference to Skyhook as referring to Skyhook Wireless, Inc. 19. Google objects to the definition of “Skyhook Technology” as vague, ambiguous,

and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, as seeking a legal conclusion, as seeking expert testimony, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence, and as seeking information that is not within Google’s knowledge, possession, custody, or control to the extent that it purports to include “Skyhook’s intellectual property, products, proposed products, systems, or processes, including the inventions claimed in Skyhook’s patents, Skyhook’s Wi-Fi positioning system, and Skyhook’s XPS positioning system.” 20. Google objects to the definition of “Software” as vague and ambiguous, overly

broad and unduly burdensome, and irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or is not reasonably calculated to lead to the discovery of admissible evidence. 21. Google objects to the definition of “Android” and “Android OS” to the extent that

it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; as vague, ambiguous, and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence.

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22.

Google objects to the definition of “Android Enabled Mobile Phone or Tablet” to

the extent that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties; as vague, ambiguous, and subject to more than one reasonable interpretation, as overly broad and unduly burdensome, and as irrelevant to the claims or defenses asserted in this action or the subject matter of this action, or not reasonably calculated to lead to the discovery of admissible evidence. OBJECTIONS TO INSTRUCTIONS 1. Google objects to Instruction A to the extent that it is inconsistent with or seeks to

impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties, including without limitation to the extent that it purports to require production of “information in the possession of Your present and former attorneys, accountants, advisors, representatives, agents, employees, or other persons directly or indirectly employed by, or connected with, You or Your attorneys, and anyone else otherwise subject to Your control.” 2. Google objects to Instruction B to the extent that it is inconsistent with or seeks to

impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties, including without limitation rules, orders, agreements, or stipulations concerning production of electronically stored information. 3. Google objects to Instruction C to the extent that it is inconsistent with or seeks to

impose on Google obligations greater than or different from those imposed under the Federal

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Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties. 4. Google objects to Instruction D on the grounds that it is an improper interrogatory

and to the extent that it is inconsistent with or seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties. 5. Google objects to Instruction E-G to the extent that they are inconsistent with or

seeks to impose on Google obligations greater than or different from those imposed under the Federal Rules of Civil Procedure, the Court’s Local Rules, any applicable orders entered by the Court, or any stipulations of the parties.

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CERTIFICATE OF SERVICE I, the undersigned, hereby certify that I am a citizen of the United States, over the age of 18, and am not a party to the within action. I am employed in the City of Redwood City, County of San Mateo, and my business address is 333 Twin Dolphin Drive, Suite 400, Redwood Shores, California, 94065. I am readily familiar with the firm’s practice of collection and processing of documentation for business mailing. On May 2, 2013, following ordinary business practices, I served the foregoing document entitled GOOGLE INC.’S OBJECTIONS AND RESPONSES TO SKYHOOK WIRELESS, INC.’S THIRD SET OF REQUESTS FOR PRODUCTION on the parties in this action by causing a true copy thereof to be emailed to the addressees at the e-mail addresses indicated below:

Dear
Sanjeet
and
Tom, This
email
responds
to
the
following
two
issues
addressed
in
Tom's
email
attached
below:
ESI
Search
Terms
for
Skyhook
2
and
Mr.
Brin's
document
production.
This
also
includes
the
search
strings
we
are
proposing
for
production
of
documents
related
to
Apple,
which
Sanjeet
and
I
discussed. ESI
RELATED
ISSUES-­‐-­‐ First,
Google's
apparent
failure
to
identify
any
documents
for
production
pursuant
to
Skyhook's
Third
Set
of
RFPs
nearly
1
month
after
these
responses
were
due
and
its
failure
to
identify
any
additional search
terms
relevant
to
that
set
of
requests
and
Skyhook's
9
patents
asserted
in
Skyhook
2
is
improper.
Google's
position
that
no
additional
documents
ought
to
be
collected
is
untenable
given
that
Skyhook
has
asserted
an
additional
9
patents
since
Google
has
created
its
original
search
term
lists
and
that
list
(as
shown
below)
is
clearly
deficient.
We
reserve
our
rights
with
respect
to
these
issues,
but
in
an
attempt
to
move
the
process
along,
and
responding
to
Google's
request
that
Skyhook
identify
search
terms,
we
do
so
below.
Please
note
that
this
does
not
absolve
Google
from
searching
for
responsive
documents
on
its
shared
drives,
wikis
and
similar
repositories
(collectively,
"shared
repositories"),
and
to
the
extent
possible,
the
same
search
terms
should
be
applied
to
Google's
shared
repositories.
I.
PLEASE
AMEND
THE
EXISTING
LIST
OF
SEARCH
TERMS
AS
FOLLOWS: •
Many
of
Google’s
searches
have
proximities
of
two
to
five
words.
This
is
too
limiting.
Therefore,
for
at
least
the
search
strings
highlighted
in
yellow
in
the
attached,
please
replace
those
proximities
with
W/10.
•
Add
patent
numbers
for
Skyhook’s
Patents
in
its
Amended
Complaint
that
are
not
on
Google’s
ESI
list
already,
including
adding
the
full
patent
numbers
and
also
the
three
last
numbers,
for
example,
the
following
string
for
the
219
patent:
8054219
or
8,054,219
or
“*219
w/5
patent” •
Add
WLAN
or
wireless
to
each
string
involving
Wi-­‐fi
II.
PLEASE
ADD
THE
FOLLOWING
SEARCH
STRINGS: •
WPS •
Android
w/20
(cityblock
or
“citi
block”
or
streetview
or
“street
view”
or
driv!) •
Android
and
((AP
or
"access
point"
or
wifi
or
wi-­‐fi
or
Wi?Fi
or
WLAN
or
wireless)
w/10
(collect!
Or
scan!
Or
target
or
area
or
all
or
substantial!)) •
Collect!
w/5
(Android
or
user
or
handset
or
mobile) •
(Wifi
or
Wi?Fi
or
wi-­‐fi
or
wireless
or
WLAN
or
"access
point*"
or
AP
or
(Google
w/5
Location)
or
GLL
or
GLS
or
LBS)
w/20
(advertis!
or
"ad"
or
"ads"
or
"LBA*") •
Android
w/3
(advertis!
or
“ad”
or
“ads”
or
“LBA*”) •
("mobile
advertis!
"
or
"local
advertis!"
or
"location-­‐based
advertis!
"
or
"hyperlocal
advertis!"
or
"local
ads"
or
“mobile
ads”
or
“location-­‐based
ads”
or
“hyperlocal
ads”
or
“LBA*) W/20
(strategy
or
plan) •
("mobile
advertis!
"
or
"local
advertis!"
or
"location-­‐based
advertis!
"
or
"hyperlocal
Page
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Case 1:10-cv-11571-RWZ Document 196-7 Filed 07/01/13 Page 3 of 12

advertis!"
or
"local
ads"
or
“mobile
ads”
or
“location-­‐based
ads”
or
“hyperlocal
ads”
or
“LBA*”)
w/20
(analysis
OR
report
OR
survey
OR
study) •
("mobile
advertis!
"
or
"local
advertis!"
or
"location-­‐based
advertis!
"
or
"hyperlocal
advertis!"
or
"local
ads"
or
“mobile
ads”
or
“location-­‐based
ads”
or
“hyperlocal
ads”
or
“LBA*”)
w/20
royalt* •
royalt*
w/20
(LBS
or
GLS
or
NLP) •
(license
or
contract
or
eula)
and
((Google
w/10
location)
or
GLS
or
LBS) •
(mov!
Or
relocate!
Or
present)
w/10
(AP
or
"access
point"
or
wifi
or
wi-­‐fi
or
Wi?Fi
or
cache!) •
Aperture
w/10
(AP
or
"access
point"
or
wifi
or
Wi-­‐Fi
or
WLAN
or
wireless
or
cluster) •
(mov!
Or
relocate!
Or
present)
w/20
(MaxLRE
or
algorithm
or
cluster) •
(Distance
or
threshold)
and
GPS
and
(AP
or
"access
point"
or
wifi
or
cluster) •
((satellite!)
w/10
(raw
or
2
or
two
or
3
or
three))
and
(AP
or
"access
point"
or
wifi
or
wi-­‐fi
or
Wi?Fi) •
(calc*
or
estimat*
or
determine*)
w/10
(locat*
or
position*)
w/10
(error
or
accura*) •
cach!
w/10
(AP
or
"access
point"
or
wifi
or
wi-­‐fi
or
Wi?Fi
or
prefetch!
or
station!
or
move!) •
wifi.cach! •
(GPS
or
(assisted
GPS)
or
triangulat*)
and
((Google
w/5
location)
or
GLS)
and
(Wi-­‐fi
or
Wifi
or
Wi?Fi
or
WLAN
or
wireless
or
(access
w/3
point)
or
WAP
or
AP) •
(Wi-­‐fi
or
Wifi
or
Wi?Fi
or
WLAN
or
wireless
or
(access
w/3
point)
or
WAP
or
AP)
w/5
(GPS
or
locat*
or
position) •
ACD
w/50
GPS •
CDD
w/50
GPS •
Compatib*
w/50
GPS •
LocationManager
w/50
(GPS
or
satellites) •
(Qualcomm
or
“Texas
Instruments”
or
TI)
and
GPS •
Wifiscan •
ActiveCollector •
LocatorManager •
Wifilocalizerinterface •
wificlustering •
ClientlocationEstimation •
locserver •
NetworkLocator •
Aple •
WifiLocationEstimator •
MaxLreLocalizer •
WifiLocator •
Wifilocalizer •
Wifipoint •
ClientReporter •
NetworkLocationClient •
ap_stats •
gls_locator •
GlsClient •
GlsLocatorResult (“MacWorld”
or
“Mac
World”)
and
(Apple
or
Jobs
or
location
or
driv*
or
beacons
or
triangulat*)
(Apple
or
Jobs)
and
(location
or
WiFi
or
Wi-­‐Fi
or
wireless
or
WLAN)
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Case 1:10-cv-11571-RWZ Document 196-7 Filed 07/01/13 Page 4 of 12

Second,
we
propose
Thursday
at
4
PM
Eastern
for
the
exchange
of
Skyhook's
search
terms
and
custodians
from
the
state
court
case
and
Google's
clear
identification
of
the
custodians
and
search
terms
applied
in
each
of
the
two
cases.
MR.
BRIN'S
DOCUMENTS-­‐-­‐ As
I
told
Sanjeet
on
our
meet
and
confer
on
Friday,
Skyhook
cannot
just
accept
Google's
representation
that
its
search
of
Mr.
Brin's
documents
yielded
no
relevant
document.
As
a
compromise,
we
are
willing
to
significantly
narrow
the
list
of
search
terms
for
Mr.
Brin's
documents,
so
we
propose
that
Google
run
only
the
following
searches
on
Mr.
Brin's
emails
and
other
files
and
produce
all
documents
responsive
to
those
searches: i.
Skyhook ii.
(Ted
or
Edward)
w/3
Morgan iii.
(Mike
or
Michael)
w/3
Shean iv.
(“MacWorld”
or
“Mac
World”)
and
(Apple
or
Jobs
or
location
or
driv*
or
beacons
or
triangulat*)
v.
“Location-­‐based
services”
or
LBS
or
GLS vi.
(“Location”
or
Wi-­‐Fi
or
WiFi
or
Wi?Fi
or
wireless
or
WLAN)
and
(advert*
or
revenue
or
value) Please
get
back
to
us
on
both
of
these
issues
no
later
than
Friday,
June
7,
but
please
do
confirm
your
agreement
to
the
Thursday
exchange
tomorrow.
Thank
you. Best,
Azra
AZRA
HADZIMEHMEDOVIC

and follows up on our meet and confer call Friday and your request that Google provide responses by today on certain specific issues that you raised. I. Response To Your Below Message Sent This Afternoon A. Google’s Motion to Limit Number of Asserted Claims and Require New Infringement Contentions Your response to Google’s good faith attempt to meet and confer to narrow the dispute misses the point of Google’s motion. Google’s motion seeks to reduce the number of claims in suit to reduce the unreasonable burden (i) on Google in having to provide non-infringement and invalidity contentions for at least 89 claims, (ii) on Skyhook in having to analyze Google’s contentions, and (iii) on the court in potentially having to address disputes about those contentions. This is particularly the case where Skyhook concedes that the number of claims needs to be narrowed or limited, but asserts that it is premature to do so at this stage – in part because Skyhook has not received non-infringement and invalidity contentions from Google. It is not premature for Skyhook to limit the claims in suit to those that it reasonably expects to assert at trial. This is true at least for the reason that Skyhook’s expert has been reviewing Google’s source code that explains the operation of the accused products for years at this point, and as a result Skyhook should be in a position to narrow its claims. This fact distinguishes the situation in this case from other cases where claims were narrowed at a later stage. As for Skyhook’s suggestion that its narrowing of its claims in suit should be contingent upon Google’s agreement to limit the number of invalidity references on which it will rely, the number of Google’s invalidity references will be narrowed by necessity when Skyhook limits the number of claims in suit – no separate agreement is necessary on that point. Second, concerning the separate issue of Skyhook’s infringement contentions, your response again misses the point. It would be unduly burdensome and wasteful for Google to respond to, and the parties to have to engage in discovery concerning, invalidity contentions that are deficient when the contentions can and should be corrected, and should be focused on a more limited set of claims in suit. As you know, Google’s invalidity contentions and the agreed-to non-infringement contentions are due on June 15. We have made clear the basis for Google’s motion and attempted in good faith to resolve or narrow the dispute, but Skyhook has refused. Unless Skyhook is willing to reverse the position stated in your below response, to meaningfully limit its claims prior to the deadline for Google’s invalidity and non-infringement contentions, Google intends to file its motion and to seek expedited consideration by the Court. B. Corporate and Individual Depositions We again confirm that Google will designate corporate representative witnesses for some topics pending the resolution of its motion for protective order. As we understand your below message, that confirmation addresses most of your questions. With respect to the timing of Google’s designations, Google will work with Skyhook to determine a mutually agreeable date and time when both parties are prepared to identify designees and discuss the scheduling of corporate witnesses, and to discuss the scheduling of the noticed individual depositions. Google has asked for dates for Skyhook’s corporate and individual deponents. To date, Skyhook has not suggested a date and time when it is prepared to designate and discuss scheduling of its witnesses. As noted below, Sanjeet will be available on Friday to continue the conferral concerning Google’s responses to Skyhook’s document requests, and to begin the discussion concerning scheduling, which will need to encompass some dialog concerning witness availability to avoid double-tracking depositions. Responding to your “more general point” under this heading, Google committed to further
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Case 1:10-cv-11571-RWZ Document 196-7 Filed 07/01/13 Page 6 of 12

consideration of several topics raised in our conferrals on May 16 and 20 concerning Skyhook’s 30(b)(6) notice. We have responded concerning Google’s position concerning some of those, we respond below to your repeated requests concerning others, and we continue to consider still others. As I noted in our Friday conferral, we are in the process of parsing and responding to your 18-page letter sent Thursday, which unhelpfully reiterates positions set forth in your previous letters rather than focusing on and summarizing the parties discussions, and we will respond to remaining issues in that letter in due course. C. Ongoing and Upcoming Conferrals We believe that the below information addresses most of your message under this heading. As I stated during our conferral last Friday, I am not available at any time this Friday. Sanjeet will be available on Friday at 2 p.m. PDT. Thank you for informing us that you represent Mr. Fjeldsoe-Nielsen. We look forward to receiving alternate dates that are in the near future. II. Follow-Up On Friday Conferral And Requested Responses A. ESI Exchange/Information First, the parties exchanged certain ESI information approximately two months ago, on March 27, 2013. Google provided a consolidated list of shared ESI locations, custodians, and search terms used for both the state case and the Skyhook I case, inasmuch as the documents were deemed cross-produced; Skyhook provided a list of shared ESI locations, custodians, and search terms used for the Skyhook I case. Following that exchange, Skyhook posed certain questions concerning Google’s ESI disclosure, and Google answered all of Skyhook’s questions and, in one example, agreed to provide a separate list of custodians and search terms for each of the state and Skyhook I cases, if Skyhook would agree to provide the same. See my April 22, 2013 email message to you. At the same time that Google provided answers to all of Skyhook’s initial questions, Google asked certain initial questions of Skyhook. See id. Skyhook did not answer Google’s questions. Instead, Skyhook stated that a reciprocal exchange of information would be agreeable, but made that exchange contingent upon Google’s responding to another set of questions from Skyhook. See your May 2, 2013 email message to me. As we have discussed multiple times since then, Google is working diligently to determine whether it has and can provide to Skyhook answers to those additional questions. At this time, we can provide answers to three of the six questions, noted below. While Google continues to investigate the remaining questions, to move the ESI discussion or conferral forward, we propose that (1) the parties exchange the agreed-to information, i.e., the separate lists of shared sources, custodians, and search terms for the state and Skyhook I cases; and (2) Skyhook provide answers to the three questions that Google asked on April 22. Google’s three questions are akin to the five questions that Skyhook initially asked, and that Google fully answered, and there is no reason why Skyhook’s responses to those questions should be contingent upon Google answering all six of Skyhook’s additional questions. If Skyhook agrees to the exchange in Item (1), but not to provide the answers in Item (2), please explain the basis for Skyhook’s refusal. This proposal moots Skyhook’s threatened motion to compel on this issue stated in your below message. The three answers to the questions in your May 2 email that we can provide now are: “(1)
Based
on
your
email,
we
understand
that
Google
has
provided
to
us
a
combined
collection
of
terms
and
custodians
for
state
and
federal
cases.
Google
should
explain
which
terms
it
used
and
which
custodians
it
searched
for
each
of
the
actions
and
for
which
time
periods.” Google agrees to provide this information as part of the reciprocal exchange of separate lists for the state and Skyhook I cases.
“(5)
What
are
"CLL
and
MADA
documents"
you
referred
to?”

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Case 1:10-cv-11571-RWZ Document 196-7 Filed 07/01/13 Page 7 of 12

“(5)
What
are
"CLL
and
MADA
documents"
you
referred
to?” CLL stands for “Client Location Library”; MADA stands for “Mobile Application Distribution Agreement.” We have agreed to identify for Skyhook the document production numbers of those documents in Google’s production. Our initial identification of CLLs/MADAs, or documents concerning CLLs/MADAs, includes documents bearing the following production numbers: GOOGSKYFED_0532029, GOOGSKYFED_0532032, GOOGSKYFED_0532064, GOOGSKYFED_0532120, GOOGSKYFED_0532488 - GOOGSKYFED_0532499, GOOGSKYFED_0532500 - GOOGSKYFED_0532522, GOOGSKYFED_0532548 GOOGSKYFED_0532569, GOOGSKYFED_0532570 - GOOGSKYFED_0532580, GOOGSKYFED_0532584 - GOOGSKYFED_0532585, GOOGSKYFED_0532701 GOOGSKYFED_0532710, GOOGSKYFED_2477194 - GOOGSKYFED_2477861, GOOGSKYFED_2477862 - GOOGSKYFED_2477909, and GOOGSKYFED_2478565 GOOGSKYFED_2478586. “(6)
Did
Google
apply
search
terms
to
the
"shared
sources"
(defined
above
under
2),
and
if
so,
which
search
terms
were
applied
to
which
shared
source
and
for
which
time
period?” Google applied the search terms to the custodian sources. Documents gathered from shared sources were identifiable by category. B. Search Terms for “Skyhook II” Patents You demanded, under the threat of a motion to compel, that Google provide a response by today on whether Google was willing to apply additional search terms for the Skyhook II patents and, if so, what search terms. As we have stated in previous conferrals, Google’s initial assessment was that no additional search terms would be required as a result of the inclusion of the Skyhook II patents, inasmuch as the same accused products are at issue for which documents already have been identified, gathered, and produced. We stated that Google was carefully continuing to evaluate that position, and having done so, Google maintains that position. Google is willing to consider, and confer with Skyhook on a list of additional terms that Skyhook believes are relevant to the Skyhook II patents that are not included within or fairly represented by the list of search terms used in the Skyhook I and state cases. Skyhook has had Google’s consolidated list of search terms used in those cases for more than two months, yet it has not proposed any additional terms that it believes Google should use. Google has conducted its analysis and concluded that none are required; if Skyhook wishes to propose additional terms, Google is willing to consider them. Any motion practice concerning ESI terms for Skyhook II would be premature until Skyhook proposes a list of additional terms that it believes are required and Google has had a chance to consider them, and this proposal moots Skyhook’s threatened motion to compel on this issue. C. RFP 316 of Skyhook’s Third Set of RFPs, seeking documents of Sergey Brin You demanded, under the threat of a motion to compel, that Google provide a response by today to the question of whether there was a subset of search terms that it would agree to use to search Mr. Brin’s documents, and if so that Google provide a “concrete proposal” as to those search terms. Google maintains its position that Skyhook has failed to show any reason to believe that Mr. Brin has any personal knowledge of any issues relevant to the claims or defenses in this action and, accordingly, has failed to show any basis for searching Mr. Brin’s documents. Without waiving or in any way deviating from that position, in response to your request, Google’s proposal is that it search Mr. Brin’s emails for the terms “Skyhook,” “Ted Morgan,” and “Macworld.” Google has performed those searches. No documents indicating that Mr. Brin has any personal knowledge of any issue relevant to the claims or defenses in this action have resulted. This proposal and searches moot Skyhook’s threatened motion to compel on this issue.
Page
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Case 1:10-cv-11571-RWZ Document 196-7 Filed 07/01/13 Page 8 of 12

D. RFP 223 and 224, seeking license agreements and settlement agreements Google has identified certain CLL and MADA agreements in its production, and explained the meaning of those acronyms, above. Google will be producing additional settlement agreements that it has identified that may be responsive to these requests. Google currently is not aware of any additional documents responsive to these requests. Once Skyhook has reviewed the CLL and MADA agreements that Google produced, some as long ago as November 2012, and that Google has identified in its production, if Skyhook has additional questions, Google will endeavor to respond. This response moots Skyhook’s threatened motion to compel on this issue. Please let us know when we can expect to receive the supplemental Skyhook production of recent technology agreements, e.g., with Comodo, that Skyhook agreed to produce. E. Identification of Location of Google Servers You demanded, under the threat of a motion to compel, that Google provide a response by today on the proposal in your 18-page letter sent Thursday that Google provide City and State information for the location of its servers. Google does not agree to Skyhook’s proposal. As Google has stated on previous occasions, the location of Google’s servers in the United States is not relevant to any issues in this action. Google has offered to stipulate that Google servers are located in the United States, and that requests from within the United States go to servers located in the United States. Google has noted that such a stipulation, or a sworn interrogatory response, has the same evidentiary value to Skyhook as witness testimony. Nevertheless, although Google will not produce documents identifying the location of its servers, it will designate a corporate witness to testify to the facts as stated in Google’s proposed stipulation. This agreement moots Skyhook’s threatened motion to compel on the issue of a corporate representative on this topic. F. Worldwide Data As we agreed to do in our conferral concerning Google’s objections to Skyhook’s Amended Rule 30(b)(6) Notice, Google has further considered its position on production of worldwide data. Google maintains its position that worldwide data is not relevant to any claims or defenses in this action. We have considered your suggestion of “scenarios” where worldwide data purportedly might be relevant, including purportedly in connection with objective indicia of nonobviousness, and we disagree with your arguments. G. Documents Concerning Advertising Revenue As we agreed to do in our conferral concerning Google’s objections to Skyhook’s Amended Rule 30(b)(6) Notice, Google has further considered whether any additional financial information concerning location-related advertising can be produced. Without waiving its objections and position that such information is not relevant to any claims or defenses in this action, Google has identified and will produce additional financial documents concerning mobile advertising revenue. Google already has agreed to designate corporate witness(es) to testify concerning the financial documents produced in this action, and such witness(es) will be prepared to testify concerning these additional documents. This agreement moots Skyhook’s threatened motions to compel concerning corporate representative testimony and document production. H. Identification of Dashboards

In our conferral concerning Google’s objections to Skyhook’s Amended Rule 30(b)(6) Notice, Google agreed to identify the dashboards that it has produced. The Dashboards are in the following document production number range GOOGSKYFED_0000001 – GOOGSKYFED_0007899.
Page
7
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Tom,
thank
you
for
your
message
below.
Google's
Threatened
Motion
Regarding
Number
of
Asserted
Claims
and
Infringement
Contentions First,
Google's
request
that
Skyhook
limit
its
asserted
claims
on
the
11
patents-­‐in-­‐suit
to
a
total
of
20
at
this
stage
is
premature.
Google
has
not
yet
served
its
invalidity
or
non-­‐infringement
contentions,
has
not
provided
a
single
fact
witness
in
corporate
or
individual
capacity,
and
has
not
even
commenced
its
production
relevant
to
the
9
"Newly
Asserted"
patents.
Nothing
in
the
cases
Google
has
identified
to
us
suggests
otherwise,
and
in
fact,
those
cases
support
Skyhook's
position.
We
are
willing
to
entertain
a
meaningful,
reciprocal
agreement
where
Skyhook
would
narrow
the
number
of
claims
and
Google
would
narrow
the
number
of
invalidity
references,
and
we
are
willing
to
discuss
the
appropriate
timing
for
such
narrowing
and
even
limits
that
may
make
sense.
But
to
be
clear,
the
time
for
such
narrowing
is
not
now.
Second,
we
see
no
reason
why
it
would
be
appropriate
at
this
time
to
amend
Skyhook's
contentions
to
respond
to
the
few,
minor
alleged
deficiencies
Google
has
identified,
and
moreover,
how
these
alleged
issues
could
be
in
any
way
impeding
Google's
ability
to
provide
non-­‐infringement
or
invalidity
contentions.
Skyhook
intends
to
take
discovery
on
the
areas
Google
identified,
and
we
are
willing
to
prioritize
related
corporate
and
individual
depositions,
but
without
such
discovery,
we
do
not
believe
it
is
proper
to
seek
our
amendments
now.
This
is
so
in
particular
because
Google
should
be
more
than
able
to
serve
its
noninfringement
contentions
in
response
to
Skyhook's
existing
contentions.
For
example,
Google
complains
that
Skyhook
accused
the
Gears
API
that
may
have
been
discontinued
during
a
portion
of
time
for
which
Skyhook
may
be
seeking
damages.
First,
we
need
to
take
discovery
to
ascertain
the
exact
timing
of
the
transition
from
the
Gears
API
to
a
new
API
and
the
circumstances
surrounding
it.
Your
current
interrogatory
response
on
the
issue
is
not
sufficient
and
does
not
warrant
our
supplementation
at
this
time.
Second,
it
is
Google
who
should
know
when
and
how
Google
switched
from
Gears
API
to
the
API
it
currently
uses
and
it
can
provide
that
detail
in
its
noninfringement
contentions.
Similarly,
with
respect
to
whether
Google
believes
that
it
is
Qualcomm
chip
that
performs
some
of
the
infringing
functionality
for
the
219
patent,
Google
should
state
the
basis
for
its
belief
in
its
noninfringement
contentions,
and
Skyhook
plans
to
examine
Google's
witnesses
on
the
scope
of
their
knowledge
about
this
functionality.
In
short,
even
if
the
few
alleged
deficiencies
in
Skyhook's
contentions
were
real,
which
they
are
not,
they
are
not
a
reason
to
postpone
Page
8
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Case 1:10-cv-11571-RWZ Document 196-7 Filed 07/01/13 Page 10 of 12

the
service
of
Google's
contentions.
Corporate
and
Individual
Depositions With
respect
to
scheduling
of
Skyhook's
corporate
depositions
of
Google's
witnesses,
we
understand
from
your
last
email
that
Google
will
not
insist
on
waiting
for
the
Court
to
resolve
Google's
motion
for
protective
order,
but
will
proceed
to
schedule
corporate
depositions.
Will
you
be
ready
this
Friday
to
identify
your
corporate
witnesses,
the
topics
they
will
be
testifying
about,
and
their
availability
and
also
confirm
individual
noticed
deponents'
availability
?
Further,
if
we
misunderstood
your
last
email
(and
you
are
refusing
to
schedule
any
corporate
depositions),
then
please
confirm
that
you
will
proceed
to
schedule
the
individual
depositions
Skyhook
has
noticed
whether
or
not
you
expect
the
same
witness
to
be
called
later
as
a
corporate
witness
after
Google's
motion
has
been
resolved.
Please
respond
today.
On
a
more
general
point,
as
my
May
23
letter
described
in
great
detail,
Skyhook's
understanding
until
the
moment
Google
filed
its
motion
for
protective
order
was
that
Google
specifically
committed
to
reconsidering
its
objections
to
Skyhook's
Rule
30(b)(6)
topics.
We
had
requested
your
responses
on
most
topics
by
last
Friday
and
on
a
couple
of
topics
by
today.
Please
provide
those
responses
today,
and
if
you
are
not
going
to
provide
them,
please
let
us
know
so
that
we
can
accurately
reflect
the
state
of
play
to
the
Court.
Ongoing
and
Upcoming
Meet
and
Confers First,
we
are
expecting
today
your
response
on
the
Skyhook
1
and
2
ESI
issues
we
have
been
discussing.
That
is,
we
have
asked
that
you
tell
us
when
you
will
be
ready
to
exchange
information
we
have
been
discussing
and
to
tell
us
search
terms
you
intend
to
use
for
Skyhook
2
production.
Second,
we
are
available
on
Friday,
between
1
and
4
PM
Eastern,
to
continue
our
discussion
regarding
Google's
responses
to
Skyhook's
Third
Set
of
RFPs.
Please
be
prepared
to
give
us
your
responses
on
the
issues
we
have
previously
discussed.
At
the
same
time,
we
are
available
to
discuss
Skyhook's
objections
to
Google's
corporate
notice
and
Bain
Capital's
objections
to
Google's
subpoena.
We
plan
to
make
Mr.
Agarwal
available
but
only
after
Google
narrows
the
scope
of
its
document
requests
to
Mr.
Agarwal
and
Bain
and
these
third
parties
are
able
to
complete
their
production.
Of
course,
if
you
are
satisfied
with
the
scope
of
production
Bain
and
Mr.
Agarwal
have
agreed
to
produce,
we
will
proceed
under
that
agreement.
Third,
we
represent
Mr.
Lars
Fjeldsoe-­‐Nielsen.
Due
to
a
previously
planned
trip
to
China,
he
is
not
available
on
the
noticed
date,
but
we
should
be
able
to
provide
an
alternative
date
shortly.
Thank
you.
Best,
Azra

Azra and Aaron – I’m writing to follow up on two issues discussed in our conferral this afternoon. First, you asked whether the filing today of Google’s Motion For Protective Order with respect to Skyhook’s Second Amendment to Rule 30(b)(6) Notice meant that Google would refuse to provide any corporate representative witnesses until the motion was resolved. The answer is no. As stated in the motion itself, Google does not dispute that some topics in Skyhook’s 30(b)(6) notice are relevant. We requested that Skyhook narrow the notice so that Google could prepare witnesses and the parties could move forward, but Skyhook refused. Nevertheless, Google is willing to provide corporate representative witnesses for reasonable topics of reasonable scope. In connection with the scheduling of Rule 30(b)(6) witnesses, please let us know when Skyhook is prepared to discuss scheduling of its designees in response to Google’s Rule 30(b)(6) Notice. Second, we met and conferred concerning Google’s request that Skyhook reduce the number of claims in suit from at least 89 currently to a maximum of 20 or 30. I provided you several reasons why we believe that such a reduction would promote judicial economy and efficient management of the case for the parties and the Court. We also discussed Google’s request that Skyhook provide new infringement contentions for the reduced set of patent claims that correct inadequacies in its current infringement contentions. You asked that we provide you with our requests, bases therefor, and supporting authority in writing. In response, I’ve attached a draft of a motion requesting that the Court issue an order requiring Skyhook to reduce the number of asserted claims and provide adequate infringement contentions. The draft motion is provide in connection with Google’s good faith attempt to narrow the dispute and without prejudice to its right to modify the motion before filing, if Skyhook does not agree to the relief Google is requesting. In view of the imminent deadline for Google’s invalidity contentions, and agreed-to non-infringement contentions, please let us know by Wednesday whether Skyhook is willing to reduce the claims in suit and to provide new infringement contentions. Regards,
Page
1 0
of
1 1

King & Spalding Confidentiality Notice: This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message.

Dear
Bill, We
have
produced
the
TracBeam
settlement
agreement,
and
as
required
by
that
agreement,
we
have
marked
it
Highly
Confidential
‹
Attorneys'
Eyes
Only.
That
is,
Google's
in-­‐house
counsel
or
any
Google
employees
cannot
have
access
to
it.
Further,
our
production
pursuant
to
Google's
RFP
61
is
complete.
We
similarly
request
that
Google
produce
to
Skyhook
the
documents
produced
in
TracBeam
case,
including
discovery
responses
and
depositions,
to
the
extent
that
those
materials
relate
to
Google
Location,
Google
Location
Service,
or
Location-­‐Based
Advertising.
See,
e.g.,
Skyhook's
RFPs
5,
6,
and
122.

You
have
not
responded
to
my
February
25
email
regarding
Mr.
Brin's
deposition.
Please
confirm
if
Skyhook
will
withdraw
the
deposition
notice.
If
not,
Google
will
bring
a
motion
for
protective
order
that
the
deposition
not
proceed.

Dear
Azra
-­‐ You
have
not
provided
any
support
for
your
"understanding
...
that
Mr.
Brin
is
knowledgeable
on
these
topics
and
could
offer
testimony
and
perspective
that
is
not
directly
available
to
Google's
other
witnesses."
What
is
the
basis
for
this
understanding?
We've
asked
you
several
times
for
this,
but
you
have
not
provided
any
evidence
to
support
it. Mr.
Brin
is
a
founder
and
senior
leader
of
one
of
the
largest
companies
in
the
world.
Skyhook
bears
the
initial
burden
of
showing
that
a
person
in
Mr.
Brin's
position
has
unique
knowledge
on
relevant
subject
matter,
i.e.,
not
just
his
own
perspective
on
information
available
from
others
or
through
other
means.
In
addition,
Skyhook
must
have
actually
sought
the
information
in
another,
less
burdensome
way
before
seeking
this
deposition
and
establishing
that
it
is
necessary. Skyhook
has
not
met
any
of
its
burdens,
and
there
is
no
basis
for
imposing
on
Mr.
Brin
given
the
lack
of
any
showing
by
Skyhook
as
we
have
stated.
The
deposition
notice
appears
tactical
and
intended
to
harass
Mr.
Brin
and
Google,
particularly
given
that
the
notice
is
served
at
the
beginning
of
taking
depositions
in
the
case,
before
Skyhook
has
examined
any
witnesses
regarding
relevant
subject
matter.
We
are
prepared
to
seek
a
protective
order,
and
sanctions,
if
Skyhook
does
not
withdraw
the
deposition
notice
for
Mr.
Brin. Bill

Tom, Thank
you
for
following
up
on
our
conversation
on
Friday.
Yes,
the
parties
have
agreed
to
reschedule
the
currently
noticed
depositions
and
have
also
agreed
not
to
wait
for
the
Court
to
hold
the
hearing
regarding
Google's
motion
to
consolidate,
but
to
proceed
in
the
meantime
to
work
on
rescheduling
the
previously
noticed
depositions. With
respect
to
Skyhook's
requests
for
Mr.
Brin's
deposition
and
production
of
relevant
email,
Google
confirmed
that
it
has
not
in
fact
spoken
to
Mr.
Brin
to
determine
whether
he
has

Case 1:10-cv-11571-RWZ Document 196-9 Filed 07/01/13 Page 4 of 5

information
relevant
to
Skyhook's
case.
Skyhook
therefore
requests
that
Google
specifically
confirm
with
Mr.
Brin
whether
he
has
relevant
knowledge
in
the
following
areas: (1)
attendance
and
participation
at
Macworld
2008,
including
discussions
relating
to
Skyhook's
or
Google's
location
technology; (2)
discussions
with
Apple
regarding
Google's
location-­‐based
services; (3)
direction
and
management
of
the
development
of
Google's
location-­‐based
services; (4)
value
of
location-­‐based
data
to
Google; (5)
knowledge
of
and
participation
in
discussions
relating
to
Skyhook's
location
technology
and
Google's
valuation
and
knowledge
about
that
technology;
and (6)
decisions/discussions
regarding
the
Motorola
and
Samsung
deals
and/or
potential
deals
with
Skyhook
relating
to
location
technology. If
Mr.
Brin
is
willing
to
submit
a
declaration
that
he
has
not
participated
in
the
activities
outlined
above
and
does
not
have
any
firsthand
knowledge
in
these
areas,
then
we
would
be
willing
to
consider
withdrawing
our
deposition
notice
and
request
for
Mr.
Brin's
email.
Our
understanding,
however,
is
that
Mr.
Brin
is
knowledgeable
on
these
topics
and
could
offer
testimony
and
perspective
that
is
not
directly
available
to
Google's
other
witnesses.
Further,
unless
Mr.
Brin
is
willing
to
declare
under
oath
that
he
in
fact
has
no
relevant
knowledge
related
to
Skyhook's
case,
Google's
objection
to
conducting
targeted
searches
of
his
email
on
the
limited
topics
Skyhook
has
identified
is
improper. Best,
Azra
AZRA
HADZIMEHMEDOVIC

TENSEGRITY
LAW
GROUP
LLP 555
Twin
Dolphin
Drive,
Suite
360 Redwood
Shores,
CA
94065 650-­‐802-­‐6055
(phone) 202-­‐321-­‐3879
(mobile) 650-­‐802-­‐6001
(fax) On
2/15/13
5:41
PM,
"Lundin,
Tom"
<TLundin@KSLAW.com>
wrote: Azra
-­‐-­‐ I'm
confirming
our
conversation
earlier
today.
We
agreed
that,
with
respect
to
the
depositions
noticed
by
each
party
thus
far,
neither
party
has
the
expectation
that
the
depositions
will
occur
on
the
dates
set
forth
in
the
notices/subpoenas.
With
one
exception,
noted
below,
the
parties
will
continue
to
work
on
identifying
dates
for
the
noticed
witnesses
and
will
communicate
further
on
potential
rescheduled
dates.

Case 1:10-cv-11571-RWZ Document 196-9 Filed 07/01/13 Page 5 of 5

The
exception
noted
above
applies
to
the
deposition
notice
Skyhook
issued
for
Mr.
Brin.
Although
we
did
not
discuss
the
Brin
notice
today,
it
was
discussed
during
the
Rule
26(f)
conference
on
Monday,
when
Google
reiterated
its
previously
emailed
objection
and
request
that
Skyhook
withdraw
the
Brin
notice.
During
the
Rule
26(f)
conference
you
proposed
sending
us
some
information
concerning
Skyhook's
desire
to
depose
Mr.
Brin.
We
said
that
we
would
review
the
information,
but
did
not
withdraw
our
request
that
the
notice
be
withdrawn.
Please
let
us
know
whether
Skyhook
will
agree
to
withdraw
the
Brin
notice,
so
that
we
can
determine
whether
Google
needs
to
move
for
a
protective
order. Please
don't
hesitate
to
call
with
any
questions.
Have
a
good
weekend. Regards, TCL King
&
Spalding
Confidentiality
Notice: This
message
is
being
sent
by
or
on
behalf
of
a
lawyer.
It
is
intended
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or
entity
to
which
it
is
addressed.
This
communication
may
contain
information
that
is
proprietary,
privileged
or
confidential
or
otherwise
legally
exempt
from
disclosure.
If
you
are
not
the
named
addressee,
you
are
not
authorized
to
read,
print,
retain,
copy
or
disseminate
this
message
or
any
part
of
it.
If
you
have
received
this
message
in
error,
please
notify
the
sender
immediately
by
e-­‐mail
and
delete
all
copies
of
the
message.

Dear
Azra: I
write
to
respond
to
various
issues
we
discussed
on
the
phone
yesterday.
IT/e-­‐mail
Delivery When
we
spoke
yesterday,
you
stated
that
Skyhook
did
not
receive
Tom
Lundin’s
message
from
Saturday evening.
We
confirmed
that
our
local
counsel
(included
in
the
distribution)
did
receive
the
message
when
it was
sent.
You
stated
that
you
would
confirm
whether
your
local
counsel
received
the
message
and
if
there was
any
IT
issue
on
your
end.
We
want
to
make
sure
that
you
are
receiving
our
correspondence
at
the
time
it is
sent.
Skyhook’s
Proposed
Search
Terms
for
Skyhook
II (1)
Google’s
estimated
document
counts
are
estimates
that
intend
to
exclude
documents
that
are duplicative
of
the
previously
produced
documents.
(2)
Google
produced
all
responsive
documents
by
performing
a
linear
substantive (Responsive/NonResponsive)
review
of
documents
and
their
family
members
where
at
least
one
document in
the
family
had
a
hit
on
one
of
the
search
terms.
As
discussed
yesterday,
the
result
of
our
running
the
search
terms
that
your
requested
is
that
it demonstrates
that
Skyhook’s
proposed
search
terms
are
too
broad
and
need
to
be
narrowed.
For
example, these
search
strings
that
Skyhook
provided
are
especially
problematic
in
breadth: •
Apple •
Wifiscan •
ActiveCollector •
LocatorManager •
Wifilocalizerinterface •
locserver •
NetworkLocator •
WifiLocationEstimator •
MaxLreLocalizer •
WifiLocator •
ClientReporter •
NetworkLocationClient •
GlsClient •
GlsLocatorResult •
Android
w/20
(cityblock
OR
“citi
block”
OR
streetview
OR
“street
view”
OR
driv~) •
Android
AND
((AP
OR
"access
point"
OR
wifi
OR
"wi-­‐fi"
OR
Wi?Fi
OR
WLAN
OR
wireless)
w/10
(collect~ OR
scan~
OR
target
OR
area
OR
substantial~)) •
Collect~
w/5
(Android
OR
user
OR
handset
OR
mobile) •
(Wifi
OR
Wi?Fi
OR
"wi-­‐fi"
OR
wireless
OR
WLAN
OR
"access
point*"
OR
AP
OR
(Google
w/5
Location)
or GLL
or
GLS
or
LBS)
w/20
(advertis~
OR
ad
OR
ads
OR
LBA*) •
(license
OR
contract
OR
eula)
AND
((Google
w/10
location)
OR
GLS
OR
LBS) •
(mov~
OR
relocate~
OR
present)
w/10
(AP
OR
"access
point"
OR
wifi
OR
"wi-­‐fi"
OR
Wi?Fi
OR
cache~) •
(Distance
OR
threshold)
AND
GPS
AND
(AP
OR
"access
point"
OR
wifi
OR
cluster) •
cach~
w/10
(AP
OR
"access
point"
OR
wifi
OR
"wi-­‐fi"
OR
Wi?Fi
OR
prefetch~
or
station~
or
move~) •
(GPS
OR
"assisted
GPS"
OR
triangulat*)
AND
((Google
w/5
location)
OR
GLS)
AND
("Wi-­‐fi"
OR
Wifi
OR Page
1
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9

Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 3 of 10
•
(GPS
OR
"assisted
GPS"
OR
triangulat*)
AND
((Google
w/5
location)
OR
GLS)
AND
("Wi-­‐fi"
OR
Wifi
OR Wi?Fi
OR
WLAN
OR
wireless
OR
(access
w/3
point)
OR
WAP
OR
AP) •
("Wi-­‐fi"
OR
Wifi
OR
Wi?Fi
OR
WLAN
OR
wireless
OR
(access
w/3
point)
OR
WAP
OR
AP)
w/5
(GPS
OR locat*
OR
position) •
(Qualcomm
OR
“Texas
Instruments”
OR
TI)
AND
GPS •
(Apple
OR
Jobs)
and
(location
OR
WiFi
OR
"Wi-­‐Fi"
OR
wireless
OR
WLAN)
The
single
word
search
strings
are
especially
problematic.
Google
requests
again
that
Skyhook
provide
a more
reasonable
set
of
search
strings
(including,
by
way
of
example
only,
fewer
terms,
with
closer proximities,
and
with
narrower
Boolean
connectors)
that
are
more
narrowly
focused
to
target
documents that
Skyhook
contends
that
it
needs
to
prove
the
claims
asserted
in
the
consolidated
case-­‐-­‐that
would
not
be duplicative
of
the
information
found
in
the
vast
volume
of
documents
already
produced.
Production
of
Skyhook
Witness’
Personal
Documents On
our
call
yesterday,
you
asked
whether
Google
agreed
to
produce
personal
documents
of
its
witnesses two
weeks
in
advance
of
their
depositions.
Google
does
not
agree
to
search
personal
documents
of
its employees.
Skyhook
has
provided
no
reason
why
searching
Google’s
personal
documents
would
lead
to
any relevant
documents.
In
contrast,
Skyhook’s
document
production
demonstrates
that
its
employees
used personal
e-­‐mail
accounts
for
business
purposes.
(See
e.g.,
SKYFED6_000031143,
SKYFED6_000022581 relevant
to
invalidity)
Google
explained
to
Skyhook
that
it
seeks
“the
deponent’s
personal
materials
not
in Skyhook’s
possession,
custody
or
control
that
were
not
previously
produced
by
Skyhook.”
Because Skyhook’s
witnesses
were
using
personal
and
non-­‐company
emails
on
matters
relevant
to
this
case,
as demonstrated
in
Skyhook’s
production,
it
is
relevant
for
them
to
search
personal
and
non-­‐company
emails.
There
is
no
such
evidence
for
Google’s
employees.
Please
confirm
that
Skyhook
will
produce
personal documents
from
its
witnesses.
Additional
Google
Witness
Availability Vikram
Gundotra
is
available
for
his
deposition
on
July
24.
Because
Mr.
Gundotra’s
deposition
would conflict
with
the
date
we
provided
for
Arunesh
Mishra,
Mr.
Mishra
will
instead
be
available
on
July
31
for
his deposition.
Case
Schedule
In
View
of
Document
Production Google
received
Skyhook’s
ESI
Terms
for
Skyhook
II
on
June
3.
We
worked
diligently
with
Skyhook
to accommodate
Skyhook’s
overly
broad
and
burdensome
request
for
documents
beyond
the
2.5+
million pages
already
produced
by
Google.
There
was
no
delay
by
Google.
In
contrast,
Skyhook
has
not
yet completed
its
document
production
(for
example,
Skyhook’s
improperly
redacted
and
withheld
documents and
documents
responsive
to
Google’s
4th
set
of
RFPs).
Yesterday,
you
stated
that
Skyhook
would
not
agree to
discuss
a
revised
schedule
considering
Skyhook’s
new
demand
for
review
of
roughly
640,000
documents that
require
8
weeks
to
complete,
and
the
parties’
ongoing
document
productions.
Google
requests
that Skyhook
reconsider
its
position
before
inconveniencing
witnesses
whose
depositions
are
likely
to
occur before
productions
are
complete.
RFPs
199
and
304 When
we
spoke
yesterday,
you
requested
a
response
regarding
Skyhook’s
RFP
199
(All
Documents
Relating To
any
agreements
with
Motorola,
Samsung,
LG,
HTC,
any
other
OEM,
or
any
Person
Concerning
Google Location,
including
all
documents
reflecting
negotiations
concerning
any
such
agreement.)
As
discussed, Google
produced
documents
responsive
to
this
RFP
including: GOOGSKYFED_0532029,
GOOGSKYFED_0532032,
GOOGSKYFED_0532064,
GOOGSKYFED_0532120, GOOGSKYFED_0532488
-­‐
GOOGSKYFED_0532499,
GOOGSKYFED_0532500
-­‐
GOOGSKYFED_0532522, GOOGSKYFED_0532548
-­‐
GOOGSKYFED_0532569,
GOOGSKYFED_0532570
-­‐
GOOGSKYFED_0532580, GOOGSKYFED_0532584
-­‐
GOOGSKYFED_0532585,
GOOGSKYFED_0532701
-­‐
GOOGSKYFED_0532710,
Page
2
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9

Sanjeet, I understand from your voicemail today that you wish to discuss Google's production pursuant to Skyhook's ESI Terms and scheduling of related depositions. I am available at 5 Eastern/ 2 Pacific. Please call me at my desk. In fact, we were meaning to ask you for the following information so that we can determine whether we are at an impasse with respect to Google's production.
To make sure we understand Google's position, we ask for the following clarifications: (1) Please confirm whether Google's estimated document counts in Tom's email include documents duplicative of the previously produced documents. My understanding from our meet and confer is that Google's system is able to generate a number of documents that would include only the newly identified, not previously produced, documents, so please provide that number, by each individual search string. And please confirm that these counts include or may include multiple copies of the same document, so that the total number of unique documents is less than the number you provided. If you have the number of unique, or "de-duped" documents, please provide that information, by search string. (2) Google's suggestion that it would have to review every single document responsive to a search string appears inconsistent with its prior statements. Our understanding based on our discussions regarding search-term methodology has been that Google has produced all non-privileged documents that included a search term or string; that is, Google has only implemented a privilege screen, not a further relevance review. For example, we asked whether Google has produced all non-privileged documents that included the term Skyhook, and Google responded that it has. April 22, 2013 Email from T. Lundin re: ESI from Skyhook 1. If our understanding is incorrect, please let us know and explain your April 22, 2013 response. If our understanding is correct, please provide counts, by search string, for the documents that would be caught by the privilege filter and which Google then may want to review.
Could you please be prepared to provide this information to us at our meet and confer or work with your client to provide it to us by the end of the day tomorrow?
Thanks very much.
Best, Azra

Dear
Azra-­‐
We
have
discussed
at
length
since
February
that
Mr.
Brin
is
not
relevant
to
any
aspect
of
Skyhook’s
case.
Skyhook
noticed
Mr.
Brin’s
deposition
without
any
basis
other
than
to
harass
one
of
the
highest
ranking executives
and
co-­‐founder
of
Google.
Google
repeatedly
asked
Skyhook
to
explain
Mr.
Brin’s
relevance
to Skyhook’s
patent
case.
Skyhook’s
response
provided
no
basis:
“We
understand
that
Mr.
Brin
was
at
the
Macworld
event
in
January
2008
at
which
Apple
announced that
it
was
using
Skyhook's
location
technology
in
its
iPhone
and
that
Mr.
Brin
had
discussions
with Apple
representatives
about
that
announcement
and
Google's
displeasure
with
it.”
Skyhook
has
never
provided
any
basis
for
its
assertion
that
Mr.
Brin
has
any
connection
to
this
case.
We pointed
out
that
roughly
50,000
persons
attended
Macworld
in
2008
with
Mr.
Brin.
Nevertheless,
Google searched
Mr.
Brin’s
emails
for
the
terms
“Skyhook,”
“Ted
Morgan,”
and
“Macworld.”
No
documents
indicate that
Mr.
Brin
has
any
personal
knowledge
of
any
issue
relevant
to
the
claims
or
defenses
in
this
action.
Google
has
conducted
a
reasonable
search
for
documents
from
Mr.
Brin,
determined
that
the
resulting
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4
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Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 6 of 10
documents
are
not
relevant
and
has
no
obligation
to
conduct
any
additional
searches.
We
will
bring
a motion
for
protective
order
and
seek
sanctions
if
Skyhook
persists
in
this
harassment.
Regarding
the
ESI
Search
terms,
Google
responded
on
Saturday.
In
case
you
did
not
receive
it,
I
am
attaching Google’s
response
that
explains
the
large
cost
and
burden
involved
in
reviewing
and
producing
documents that
would
result
from
Skyhook’s
over-­‐broad
search
strings.
Regarding
depositions,
Google
confirms
the
availability
of
Mike
Lockwood
to
appear
on
July
23.
As
we
discussed
during
our
meet
and
confer,
Skyhook
deposed
Mr.
Brady
for
two
days
in
the
state
court action.
Mr.
Brady
explained
in
his
deposition
that
he
manages
partner
relationships.
Other
than
asserting that
the
state
court
case
is
different
than
the
current
case,
Skyhook
has
not
provided
an
explanation
why
Mr. Brady
should
be
deposed
again
and
in
this
patent
case.
Please
explain
what
knowledge
Skyhook
believes
Mr. Brady
has
that
is
specific
to
the
issues
of
this
patent
case
that
Skyhook
did
not
already
cover
in
its
two
day deposition
of
Mr.
Brady.
Mr.
Zelinka
will
be
available
for
his
deposition
on
July
10.
Google
disagrees
that
it
is
under
any
obligation
to produce
Mr.
Zelinka’s
documents,
solely
because
he
will
be
one
of
Google’s
technical
30(b)(6)
witnesses. Skyhook
has
not
provided
any
authority
or
caselaw
to
the
contrary.
As
we
discussed,
Google
has
produced millions
of
pages
of
documents
including
Google’s
source
code
that
explains
the
operation
of
Google’s product.
In
view
of
this,
Skyhook
has
not
provided
any
reason
why
Mr.
Zelinka’s
documents
are
needed above-­‐and-­‐beyond
Google’s
thorough
production
of
technical
documents.
Regarding
RFPs
254
and
255
which
both
ask
for
policies
regarding
third
party
patents,
after
a
reasonable search,
Google
has
not
located
any
such
policies.
With
regard
to
Skyhook’s
requests
for
Tracbeam
discovery,
Skyhook
has
not
explained
the
relevance
of Google’s
discovery
responses
in
Tracbeam.
The
patents
in
the
Tracbeam
case
are
not
related
to
the
patents asserted
by
Skyhook
and
accordingly,
Google
should
not
bear
the
cost
and
burden
of
producing
the transcripts
and
discovery
responses
that
are
not
relevant
to
this
action.
If
you
have
any
questions,
please
let
me
know.
Best
regards,

Dear Sanjeet,
I write to follow up on our latest June 20 meet and confer, in particular since Skyhook did not receive the follow-up responses on several of these issues on Friday, June 21, which you had committed to provide. On each of the issues addressed below (except on Mr. Zelinka's documents), unless by close of business on Tuesday Google agrees to produce documents or provide confirmations Skyhook has been seeking for

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Case 1:10-cv-11571-RWZ Document 196-10 Filed 07/01/13 Page 7 of 10
weeks now, Skyhook will move to compel production.
Individual Depositions Skyhook Noticed on May 23: Google's explanation that its in-house counsel has been unable to get availability from any of the seven deponents Skyhook noticed—for a whole month—is simply unacceptable. Google is not complying with its discovery obligations, and unless Google provides proposed dates for each of the noticed deponents by close of business on Tuesday, Skyhook will move to compel those depositions. Separately, please get back to us on our proposal that the parties forgo subpoenas for party witnesses and agree to produce nonduplicative relevant documents from those witnesses' possession.
Mr. Brin's Documents: Absent Google's response to our requests, specifically identified in my email attached below and discussed further at our June 20 meet and confer, by close of business on Tuesday, Skyhook will move to compel production of Mr. Brin's documents.
ESI Search Terms: Google has not yet responded to Skyhook's June 3 request to run additional ESI searches and produce responsive documents, and Skyhook will move to compel production absent a response by close of business on Tuesday.
Skyhook's Third Set of Document Requests: Skyhook pointed out during our meet and confer that it is still awaiting Google's responses on RFPs 199 (licenses and negotiations with OEMs) and 304 (how Google uses location data in its advertising) and Google has not yet provided a response.
Further, on RPFs 254 (policies regarding studies of Google's patents) and 255 (policies regarding comparisons of Google's products with third-party patents), to the extent Google maintains that documents responsive to these RPFs are privileged, Google must identify such documents on its privilege log.
Finally, with respect to Trackbeam litigation documents (RFP 303), Google has agreed to produce (1) documents produced in Tracbeam that have not been produced in this action and (2) transcripts of depositions taken in the Tracbeam action for witnesses who are common to both actions. Skyhook requested confirmation that Google will include its discovery responses provided in that litigation as well as all deposition transcripts (including corporate depositions). To the extent that Google deems certain of the witnesses somehow irrelevant to this litigation, Skyhook has asked that Google identify those witnesses to Skyhook. Given that these follow-up requests are all within the scope of our late May discussions, Skyhook will move to compel production absent Google's agreement to produce documents or explain its belief that it has already produced responsive documents by close of business on Tuesday.
Mr. Zelinka's Documents: Google has identified Mr. Zelinka as its corporate deponent on core technical topics, indeed he is the sole corporate deponent that Google has agreed to make available for deposition to date. You explained in the meet and confer that Google identified him as the corporate witness for these topics because he has the most comprehensive institutional knowledge among Google's employees currently working on the features of the accused products relevant to the topics on which he has been identified. Google also identified Mr. Zelinka in its January 30, 2013 second supplemental initial disclosures as one of only eleven Google employees knowledgeable about the issues in this litigation, and moreover, as one of only half-dozen employees knowledgeable about the operation of the accused products. However, Google has not collected, and has not produced, Mr. Zelinka's documents in this litigation and its position is that it will only produce Mr. Zelinka's documents if Skyhook can identify documents in Mr. Zelinka's files that it has not received from other custodians. This position is clearly improper because Google, not Skyhook, has access to Mr. Zelinka's documents, and given the importance Google has assigned to Mr. Zelinka's knowledge of the operation of the accused products by virtue of his designation as a corporate witness. Skyhook will proceed with Mr. Zelinka's deposition on July 10, reserving its right to seek production of Mr. Zelinka's documents after the deposition and to reopen or continue his deposition after Google produces his documents.

Tom, thank you for your responses. I will address several of them in this email in the hopes of streamlining our telephonic meet and confer.
First, Google has selected Mr. Zelinka as a corporate representative on some of the core technical deposition topics, yet has not named him as a custodian nor produced his documents. Under the circumstances, Mr. Zelinka's responsive documents clearly should be produced. Please confirm that you will produce Mr. Zelinka's responsive documents at least two weeks prior to his deposition.
Second, it is unacceptable that nearly one month after Skyhook noticed seven Google's employees for their individual depositions, Google has not responded with a proposed date for even one of those deponents. Google appears intent on delaying the resolution of this most straightforward issue, forcing motion practice knowing that it will take time for the opposing briefs to get filed, only so that Google will then—on the eve of the court's hearing—propose deposition dates. This very thing just happened with Google's interrogatory responses it had been refusing to provide until Skyhook filed its motion to compel. It is both unreasonable and unfair for Google to be delaying Skyhook's case in this manner and wasting both Skyhook's and the Court's resources on such issues.
Third, Skyhook's deposition notices for Messrs. Lee and Brady in this case are wholly appropriate, and Google's arguments about overlap in those witnesses' depositions between this and the state case are unavailing. Skyhook's patent infringement case is separate and different from its state tortious interference case. The technical, willfulness, and the damages issues in the patent case are specific to this case. Further, Google cannot legitimately argue that Mr. Lee's and Mr. Brady's state-case depositions that took place before their custodian productions in this case even commenced and before Google produced the bulk of its production in this case are sufficient discovery of those witnesses for this case. We repeat our request for an immediate identification of their availability as well as the availability of all individual witnesses Skyhook has noticed nearly a month ago.

i. Skyhook ii. (Ted or Edward) w/3 Morgan iii. (Mike or Michael) w/3 Shean iv. (“MacWorld” or “Mac World”) and (Apple or Jobs or location or driv* or beacons or triangulat*) v. “Location-based services” or LBS or GLS
vi. (“Location” or Wi-Fi or WiFi or Wi?Fi or wireless or WLAN) and (advert* or revenue or value)
Please explain why Google refuses to search Mr. Brin's documents for search strings v and vi. Please let us know how many documents each of our individual requested search strings yielded. (To the extent that the MacWorld search you ran yielded a large number of responsive documents, please let us know how many documents are responsive to our proposed search string no. iv, which is significantly narrower.) And please confirm that Google is refusing to produce the documents that those six search strings yield and expects Skyhook and the Court to rely on Google's representation that although responsive documents were found, not one is relevant.
I have already circulated a meeting invite and a dial-in for Sanjeet for our meet and confer tomorrow at 4 PM Eastern.
Thank you.
Best, Azra

RFP 315: Google does not believe that it has any responsive documents. Google is confirming again and agrees to produce any such documents that exist.

King & Spalding Confidentiality Notice: This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message

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Documents Similar To 13-07-01 Declaration in Support of Skyhook Motion to Compel